Privacy is important; especially when you consider the number of ways we communicate and interact these days.  That’s why we’ve put together this statement.  It explains how we collect, hold, use and disclose your personal information and who we share it with.

And because it’s guided by privacy laws, you can be sure it takes your rights seriously.  Above all, this statement is your assurance that we never take your privacy for granted and we always take the utmost care in protecting your personal information.  We call this statement our Privacy Policy and it gives you rights and tells you the undertakings we give in relation to your personal information. You have a right to request access to the personal information that we hold about you and to ask us to correct it.  You also have a right to make a complaint about how we have managed your personal information.  Our Privacy Policy tells you how to do these things and how we will deal with your request or complaint.

When you visit our website, order goods and services, or contact us, you accept that this Privacy Policy shows the way that we collect and manage your personal information.  All personal information held by us will be governed by our most recent policy posted on the www.biblestudydiary.com website.  This Privacy Policy was last updated July 2015.  If you continue to deal with us or visit our website, we will take it that you have consented to this Privacy Policy.

When we say ‘we’ or ‘us’ we mean Silvergull Pty Ltd as Trustee for Silvergull Trust ABN 98 419 813 24 (Silvergull).

Here are the questions we look at in our Privacy Policy; the answers can be found by scrolling down the page.

• What is "personal information"?

• When do we collect personal information?

• Do we collect personal information via websites?

• How do we use the personal information we collect about you?

• How do we check the quality of personal information?

• Who sees your personal information?

• Do we use your personal information for marketing?

• How do we keep your personal information safe?

• How can you see the personal information that we hold about you?

• How can you correct your personal information?

• What can you do if you have a question, problem or complaint about our use of your personal information?

What is "Personal Information"?

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable.

When do we collect Personal Information?

1. We collect Personal Information about individuals directly from those individuals or their authorised representative.
   1. When you interact with us, we may collect Personal Information, such as names, contact details and other relevant information. Some instances of this are when you:
      1. apply for access to our website
      2. use products or services
      3. contact us by telephone
      4. register for or attend seminars, presentations, meetings, webinars or our premises
      5. complete electronic, verbal or paper based registrations, feedback,  surveys, promotions, emails, instructions or enquiry forms
      6. subscribe to a publication, newsletter or mailing list
      7. apply for a job or volunteer your services
      8. provide information voluntarily
   2. We do not collect Sensitive Information without your consent and then only if it is reasonably necessary for one or more of our activities, for example for establishing access to the www.biblestudydiary.com website, for arranging catering and access to facilities, for tax advice or for investigating a complaint.

2. We may also collect Personal Information about you from a third party or from a publicly available source, but only if:

1. You have consented to such collection or would reasonably expect us to collect information in this way.
2. It was not reasonable or practical to collect this information directly from you.

Do we collect Personal Information via websites?

1. We do not collect any Personal Information about visitors to websites except when they knowingly provide it or as otherwise described below.
2. Google Analytics uses first-party cookies to track visitor interactions.  These cookies are used to store information, such as:

1. the date, time and duration of a visit;
2. whether the visitor has been to the site before;
3. what site referred the visitor to the web page; and
4. the number of users visiting the websites and the number of pages viewed

3. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity browser type or website visiting patterns; if you access our website a cookie is downloaded onto your computer's hard drive when you first log onto the website and it is automatically deleted from your hard drive after a period of thirty days.

1. Web beacons are images that originate from a third party site to track visitor activities; we currently uses web beacons to track the visiting patterns of individuals accessing the website
2. Login audit logs are used to record a user’s usage history and selections.

How do we use the Personal Information we collect about you?

1. We use the information it collects about you to:

1. Establish your access to the www.biblestudydiary.com website
2. Identify you and conduct appropriate checks
3. Communicate with you
4. Provide you with goods or services you have requested
5. Provide you with information about goods and services we reasonably believe you may be interested in
6. Provide you with general information we reasonably believe you may be interested in
7. Personalise and customise your experiences with websites
8. Help us research the needs and expectations of users and improve the provision of goods and services by us and preferred suppliers
9. Manage complaints and disputes, and report to dispute resolution bodies
10. Comply with Occupational Health and Safety regulations
11. Comply with industry codes or a lawful request

2. We will only collect and use your Personal information in accordance with this Privacy Policy or otherwise with your prior express written consent.  If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy the main consequences for you will be that we may not be able to provide you with all or some of the requested products and services.

How do we check the quality of Personal Information?

1. We take reasonable steps to ensure the personal information we collect is accurate, up to date and complete. We may do this by providing you access to edit some of your personal information, periodic update requests, when interacting with you and where practical electronic synchronisation of our databases.
2. We provide you the right to access and correct Personal Information.

Who sees your Personal Information?

1. We disclose the information about you if or when:
   1. We have your consent to share the information; or
   2. Someone acting on our behalf provides the product or service you have requested; or
   3. We reasonably believe that your actions on the website violate our Terms

2. We may disclose Personal Information to third parties but only to the extent necessary to fulfil the purposes for which the Personal Information was collected.

3. We may also disclose your Personal Information to the website host in certain limited circumstances for example ensuring that if the website experiences a technical problem it is able to operate in an effective and secure manner

4. We may disclose your Personal Information to organisations that are located in foreign countries solely for the purposes set out in this Privacy Policy provided that such disclosure is permitted under the Australian Privacy Principles.  The Australian Privacy Principles permit disclosure to a person in a foreign country where we reasonably believes that the recipient of the information is subject to a law binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles.  The foreign countries where information may be disclosed are likely to be New Zealand, USA, UK, Canada, Argentine and the Caribbean (which is where other of our affiliated entities reside) and in countries where our contracted service providers operate or store information such as virtual or cloud based operations which may include additional countries such as Hong Kong and the Philippines.
5. If you leave our website by way of any hyperlink we advertise or display, we make no representation as to the privacy policy in place in any website visited by means of the hyperlink; you are required to make your own investigation and assessment as to the privacy policy of any website visited by this means.  In particular if you visit a telecommunications site or the site of some preferred supplier mentioned on our website, please be aware that the sharing of your personal information on those sites is not within the control or oversight of this privacy policy.
6. We may collect government related identifiers from you, which will be used or disclosed only where such use or disclosure is reasonably necessary to verify your identity for the purpose of an activity we are undertaking on your behalf.

Do we use your Personal Information for marketing?

1. We may use your Personal Information to provide you with promotional material about us or the services and products offered by us and preferred suppliers.  If you do not wish to receive promotional information you can contact our Privacy Officer by emailing admin@biblestudydiary.com at any time requesting that your name be removed from our marketing lists
2. Otherwise we will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Australian Privacy Principles

How do we keep your Personal Information safe?

1. We take reasonable steps to protect and keep your Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. The ways we do this include:

1. Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information
2. Limiting physical access to our premises and files
3. Limiting electronic access to our networks, applications and files
4. Using security related hardware and software
5. Implementing personnel safe practice policies and training
6. Monitoring and reviewing our practices periodically
7. Using third parties who meet obligations under the Australian Privacy Principles.

2. We periodically consider whether we need to retain your Personal Information in order to continue providing our goods and services to you, and may destroy or de-identify your Personal Information, except where we are required by law to retain it.

How can you see the Personal Information that we hold about you?

1. You are entitled to access Personal Information that we hold about you.
2. Access to your Personal Information is subject to our being satisfied you are the individual we hold Personal Information on or the person requesting is authorised to make a request on your behalf.
3. If we delay or refuse your request to access some or all of your Personal Information it will provide you written notice of the reasons for the refusal, such as access would unreasonably impact upon the privacy of others or would not otherwise be permitted under the Australian Privacy Principles.
4. A request for access can be done in any of the following ways:

1. Email: admin@biblestudydiary.com
2. Post to: Glenvale School Nathalia 26 Harcourt Street Nathalia 3638.

How can you correct your Personal Information?

1. You can update your Personal Information at any time by contacting our relevant department or you may edit your account information and preferences on our website.
2. Otherwise our Privacy Officer will correct your Personal Information. If we find that we have no further need for your Personal Information we will permanently de-identify it or remove it from our system and destroy all record of it.  We welcome any changes to your details so as to keep our records up to date.

What can you do if you have a question, problem or complaint about our use of your Personal Information?

1. If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy or the Australian Privacy Principles in respect of your Personal Information please contact our Privacy Officer in any of the following ways:

1. Email: admin@biblestudydiary.com
2. Post to: Glenvale School Nathalia 26 Harcourt Street Nathalia 3638.

2. Alternatively you may lodge a complaint as per our Privacy Complaints Process below.

PRIVACY COMPLAINTS PROCESS

Privacy Policy

This process is to be read in conjunction with the Silvergull Pty Ltd Privacy Policy as above and words and phrases in this Process have the meanings attributed to them in the Privacy Policy.

Purpose

This policy sets out our approach to resolving complaints from individuals about the way we have dealt with their personal information, and outlines what people can expect when they make a complaint.

Management of Privacy Complaints

Privacy complaints are managed by the Privacy Officer.

The Privacy Officer will:

• Receive and acknowledge the complaint

• Seek further information from the complainant if necessary

• Thoroughly investigate the complaint

• Respond to the complainant with the outcome of the investigation

• Provide feedback to the relevant internal stakeholders

Privacy Complaint Process

1. Complaint Receipt

We ask that complaints be made in writing. The Privacy Officer may receive an oral complaint if he considers that making a written complaint would be impracticable or unreasonably onerous for the complainant.  In written complaints, complainants should:

• Include sufficient contact details to enable us to identify them

• Clearly and succinctly state the nature of their complaints

• Include sufficient information for the Privacy Officer to understand the complaints

• Provide details such as what happened, when they became aware of it, and who was involved

• State which Australian Privacy Principle they believe has been breached (if known)

• Outline the impact the event has had on them

• Include details of what they would like to see happen to resolve the complaints

Complaints can be emailed to admin@biblestudydiary.com or posted to:

Glenvale School Nathalia 26 Harcourt Street Nathalia 3638.

If a complaint is received from someone other than the individual involved, we will only proceed if we have evidence that the person submitting the complaint has authority to do so.

2. Complaint Acknowledgement

The Privacy Officer will acknowledge the complaint within five working days of receiving it.

3. Complaint Investigation

The Privacy Officer will investigate the concerns raised by the complainant.  This may involve obtaining further information from the complainant, speaking with the relevant staff members, reviewing relevant documents or client files, and obtaining technical or legal advice.

It is anticipated that in most cases, the duration of the investigation will not exceed 20 working days. If the investigation is likely to take longer than 20 days, the Privacy Officer will notify the complainant.

4. Complaint Outcome

The Privacy Officer will inform the complainant in writing as to the outcome of the investigation.

If the complainant remains dissatisfied with the response provided, they may wish to contact the Office of the Australian Information Commissioner (The Privacy Commissioner). For more details, see https://www.oaic.gov.au/

5. Internal Feedback

Where appropriate, the Privacy Officer will provide feedback, including recommendations of process improvements, to the relevant internal stakeholders to ensure continued compliance with the Australian Privacy Principles.