Privacy Notice and GDPR Statement

Thank you for visiting the Upbeat website. This online privacy policy describes how we will collect and use information from our site. Professional Advantage Pty Ltd and those entities controlled by Professional Advantage (together, Professional Advantage) are committed to collecting, handling and disclosing personal information lawfully and fairly and to taking reasonable steps to protect and safeguard personal information. Professional Advantage is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the ten National Privacy Principles set out in that Act.

This privacy policy

• Sets out how Professional Advantage, stores, uses and discloses personal information.
• Relates to personal information collected by any means and by any technology.
• Outlines how Professional Advantage makes the personal information it holds available for access to and correction by an individual.

If you have any questions about this policy, please direct them to the Privacy Officer (see contact details below).

Professional Advantage and GDPR

PA welcomes the EU General Data Protection Regulation (GDPR) as an important step forward in streamlining data protection requirements across the EU. PA will comply with applicable GDPR regulations as a data processor when they take effect on 25th May 2018. Similar to existing legal requirements, compliance with the GDPR requires a partnership between PA and our customers in their use of our services. PA will comply with the GDPR in the delivery of our service to our customers. We are also dedicated to helping our customers comply with the GDPR. We have analysed the requirements of the GDPR and are working to make enhancements to our products, contracts, and documentation to help support PA’s and our customers’ compliance with the GDPR.

Collection of personal information

Professional Advantage will, where it is reasonable or practicable to do so, collect personal information directly from an individual using a number of different methods, including collection via Professional Advantage's websites, electronic transmission (e.g. email), post, telephone, in person or portable devices. We may also collect personal information from third parties, including clients, contractors, service providers and other individuals.

Professional Advantage will only collect personal information that is necessary to promote its business, to provide its services or to conduct its activities (Primary Purpose of Collection). These activities include:

• To provide products and services to clients.
• To receive products and services from service providers and contractors.
• To maintain and promote relationships with clients, service providers and contractors.
• To provide clients and prospective clients with information on our services and products, economic and industry developments, and seminars and events that may be of interest to them.
• To recruit and maintain relationships with staff.
• To complete internal administration functions (e.g. invoicing clients).

The type of personal information collected may include names, date of birth, gender, marital status, addresses, contact details, job titles, account details and financial information.

Use of personal information

Professional Advantage will use the personal information it collects in connection with the Primary Purpose of Collection.
Additionally, Professional Advantage may use the personal information it collects for a purpose (Secondary Purpose) that is related to the Primary Purpose of Collection and in circumstances where an individual would reasonably expect us to use personal information for a Secondary Purpose.
Where Professional Advantage uses personal information to market our products and services to clients and prospective clients, recipients can contact us at any time if they no longer wish to receive this marketing information. Alternatively, individuals will be given the opportunity to 'opt out' from receiving marketing communications from us by clicking on an unsubscribe link at the end of the email.

Access, data quality, and correction

Professional Advantage will provide access to personal information about an individual upon request by that individual (although there are some exceptions to granting access e.g. where providing access would be unlawful under the Privacy Act). If Professional Advantage denies access to an individual's personal information, it will provide reasons in writing.

The procedure for gaining access is as follows:

• An individual will need to make a request for access in writing, addressed to the Privacy Officer (see contact details below).
• An individual must provide sufficient details of the information requested.
• Professional Advantage will need to verify the identity of that individual.
• Professional Advantage may need to charge an administrative fee to cover the cost of access (however, there is no fee for lodging a request for access). Professional Advantage will notify the individual of the proposed fee before proceeding.
• Professional Advantage will respond to a request as soon as reasonably practicable but by no later than 30 days of receipt of the request.
• Professional Advantage may deliver the requested information either by mail or by email.

Professional Advantage will take all reasonable measures to aim to ensure that the personal information it holds is accurate, complete and up to date. Please contact the Privacy Officer if you believe that the information we have about you is not accurate, complete or up to date.

Disclosure of personal information

Professional Advantage may disclose personal information to third parties, such as contractors, agents and service providers, to assist us with our activities and the provision of products and services to our clients. In doing so, we will take reasonable steps to ensure that these organisations are bound by obligations of confidentiality and privacy in order to protect personal information in accordance with the Privacy Act.

We may also send personal information to organisations outside Australia (including to Professional Advantage associate companies) in connection with the provision of our products and services to clients and the performance of administrative functions.

If we transfer personal information overseas, we will only do so in compliance with this privacy policy and the Privacy Act. Furthermore, we will take reasonable steps to aim to ensure that the overseas organisation receiving the information will handle that information in accordance with the Privacy Act.

Other than as outlined above, Professional Advantage will not disclose personal information to any other third party unless Professional Advantage has:

• Reasonable grounds to believe that the disclosure is required by law
• Reasonable grounds to believe that the disclosure is necessary to prevent a serious and imminent threat to a person's life, health or safety
• The consent of an individual to do so.

Information security

Professional Advantage has in place generally accepted standards of technological security for the purpose of protecting personal information from misuse, loss, corruption or destruction. Only authorised personnel have access to personal information. Such personnel are required by Professional Advantage's policies and employment contracts to maintain the confidentiality of this sensitive data.
Where personal information we hold is identified as no longer needed for any purpose for which the information may be used or disclosed under the Privacy Act, we will take reasonable steps to destroy such information e.g. by shredding in the case of paper records and other means in the case of electronic records.

Online Privacy Matters

Cookies

For statistical purposes, we may collect information through the use of 'cookies' on website activity (including the number of users who visit our websites, date and time of your visit to the Website, the pages accessed and any information downloaded, navigation patterns, the country and systems through which users have accessed the website).

Cookies are data that a website transfers to an individual's hard drive for record-keeping purposes. Cookies can facilitate a user's ongoing access to and use of a website and may be necessary to access features such as online transactions.

While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession.

The Websites may contain links/plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.

Our websites

Professional Advantage takes care to protect the personal information given to us on our websites e.g. our websites have electronic security systems in place.

Changes to our privacy policy

Professional Advantage may amend this privacy policy from time to time by posting an updated version on our websites. We encourage you to visit our websites periodically in order to remain up to date.

The amended privacy policy will supersede this version and will apply between us whether or not we have given you specific notice of any change.

What to do if you have a question or an issue

If you have any queries about this privacy policy, or if you have any issues you wish to raise with Professional Advantage about privacy, please contact us at:

The Privacy Officer
Professional Advantage Pty Ltd
Level 6, 124 Walker Street
NSW 2060, Australia
privacy@pa.com.au