Privacy Policy

1. Overview

Thank you for using Thinka (operating under Ben Roulston Group PTY LTD ACN 165 617 630) (“Thinka”, “us” or “we”).

Thinka provides learning and development workshops, activities and programs with both online and in-person delivery, as well as customised solutions for written content, e-learning modules, videos, animation and digital platforms.

Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and any related privacy codes.

This Policy outlines how we collect, use, disclose and store your personal information and lets you know how you can access that information. This Policy applies to our obligations when handling information in Australia.
Please read this Policy carefully and contact us using the details below if you have questions.

2. Consent

By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this Policy or as required or permitted by law.

If you continue using our services, then we will treat your use as your consent to us handling your personal information in accordance with this Policy.

3. What kinds of personal information do we collect and hold?

The type of personal information we collect depends on the circumstances of its collection and the nature of your dealings with us.

If you use our services, or are a staff member employee of an organisation which uses our services, this information may include:

⦁ your name;

⦁ your contact information, such as your physical address, email address and mobile number;

⦁ your employment information, such as your place of employment, job title and position description;

⦁ the results of any surveys, psychological or aptitude tests which your employer provides to us, or which you complete as part of our services;

⦁ your device ID, device type and information, geo-location information, Internet Protocol (IP) address and standard web log information; and

⦁ information contained in any communications between you and us. If you are a prospective employee or independent contractor applying to work with Thinka, we may collect the following information:

⦁ your name, address and contact details;

⦁ business registration details, such as your Australian Business Number;

⦁ your employment details and qualifications;

⦁ billing and payment information; or

⦁ information you provide to us as part of the recruitment process.
For general users that interact with us, we may collect information when you connect with us, use our website (thinka.me) or interact with our social media accounts. This may include information:

⦁ provided in communications we have with you;

⦁ about your access and use of our websites, including browser session data, device and network information, statistics on page views, acquisition sources, search queries, browsing behaviour and information gathered through internet cookies; and

⦁ your device ID, device type and information, geo-location information, IP address and standard web log information.

We do not collect sensitive information from individuals.

You may choose to not identify yourself or use a pseudonym when you contact us, such as if you lodge a complaint. However, if you choose not to provide information as requested, we may not be able to service your needs. For example, it may not be possible for us to provide you with our service if you want to remain anonymous or use a pseudonym.

We sometimes receive unsolicited personal information. In circumstances where we receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.

4. Why do we collect your personal information?

We collect your personal information primarily to provide you, or our clients, with our service of providing learning and development workshops, activities, and programs.

Some ways we use your personal information are:

⦁ for the purpose for which the personal information was originally collected, including supplying and supporting the use of our products and services;

⦁ to identify and interact with you;

⦁ to manage our relationship with you or the organisation you work for;

⦁ to respond to requests for our products or services, or to tell you about our products and services that may be of interest to you or the organisation you work for;

⦁ to perform administrative and operational functions;

⦁ to comply with any legal requirements, including any purpose authorised or required by an Australian law, court or tribunal; and

⦁ for any other purpose for which you give your consent.

In relation to the personal information of independent contractors or prospective staff members seeking employment at Thinka, we collect personal information to allow us to:

⦁ carry out our recruitment functions;

⦁ correspond with you;

⦁ fulfil the terms of any contractual relationship; and

⦁ ensure that you can perform your duties.

For general users, we may use the information we collect to better understand our users and gain insights into client behaviour.

5. How we collect your personal information?

You give it to us

We collect personal information directly from you when you:

⦁ use our services;

⦁ interact or share personal information with us via the Thinka website and social media;

⦁ if you complete a survey or test sent to you by (or on behalf of) us;

⦁ register your interest in hearing more about Thinka; or

⦁ communicate with us.

We collect it

We may also collect your personal information from third parties including:

⦁ businesses that use our services;

⦁ from publicly available sources;

⦁ service providers;

⦁ referrals who may have referred you to us; and

⦁ organisations with whom we have an agreement to share information.

We endeavour to only ask for your personal information if it is reasonably necessary for us to carry out our business activities and will generally obtain consent from the owner of the personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct. We endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.

6. Disclosing your personal information

We may disclose your personal information to the following third parties:

⦁ to businesses that use our service and are related to your engagement with us, such as your employer;

⦁ to our business or commercial partners;

⦁ to our professional advisers, insurers, dealers and agents;

⦁ third parties and contractors who provide services to us, including client enquiries and support services, IT service providers, data storage, web-hosting and server providers, marketing and advertising organisations, payment processing service providers, banks and retailers;

⦁ payment system operators and debt-recovery functions;

⦁ third parties to collect and process data; and

⦁ any third parties authorised by you to receive information held by us.
We may also disclose your personal information if we are required, authorised or permitted by law.

We may send information to third parties that are located outside of Australia. These third parties are located in the United States of America, India and Latvia although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities.

7. Using your personal information for direct marketing

From time to time, we may use your personal information to contact you to promote and market our products and services that may be of interest to you or the organisation you work for. We may also share your personal information with our commercial and business partners for marketing purposes.

You can opt-out from being contacted for direct marketing purposes by contacting us at hello@thinka.me or by using the unsubscribe facility included in each direct marketing communication we send. Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.

8. Security

We take all reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold your personal information electronically in secure databases operated by our third-party service providers.

We protect the personal information we hold by implementing the appropriate physical, electronic, and managerial measures, including encryption, firewalls and login password protocols, auditing, network segregation for sensitive information stored electronically and information handling policies or procedures.

While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed.

9. Accessing or correcting your personal information

You are able to request access to personal information we hold about you. If you would like to access your personal information, please contact us using the details below. In certain circumstances, we may not be able to give you access to your personal information in which case we will write to you to explain why we cannot comply with your request.

We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant. If you believe the personal information we hold about you should be updated, please contact us using the details below and we will take reasonable steps to ensure it is corrected if appropriate.

10. Destroying or de-identifying personal information

We destroy or de-identify personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.

11. Making a complaint

If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.

We take privacy complaints seriously. If you make a complaint, we aim to respond within 5 business days to acknowledge your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.

We will investigate your complaint and write to you to explain our decision as soon as practicable.

If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at www.oaic.gov.au.

12. Changes

We may, from time to time, amend this Policy. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our website. By continuing to use the services following any changes, you will be deemed to have agreed to such changes.

13. Contact us

All questions or queries about this Policy and complaints should be directed to:

Privacy Officer
Thinka
PO Box 5298
South Melbourne VIC 3205
Phone: 1300 THINKA
Email: hello@thinka.me

This Policy was last updated in October 2020.