Privacy policy

Geminate is committed to providing quality services to our clients and this policy outlines our ongoing obligations to clients in respect of how we manage their Personal Information. 

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.

What is Personal Information and what Personal Information do we collect? 

Personal Information is information or an opinion that identifies an individual. In general, the main types of Personal Information we collect and hold includes (but is not limited to):

  • Names
  • Contact details (including residential and postal addresses, email addresses and phone number)
  • Gender

How do we collect Personal Information?

This Personal Information is obtained in many ways including in-person interviews, correspondence, by telephone, by email, via our website [XXX], via other software platforms we use to deliver our services (e.g.  Xero Software) and from third parties. We don’t guarantee website links or policy of authorised third parties.

Sometimes you may provide us with someone else’s personal information. You must not provide that information to us unless you have their consent to do so. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

Why do we collect Personal Information?

As a provider of communication and publishing services, it may be necessary, and in some cases be a legislative and regulatory requirement, for us to collect and hold detailed Personal Information.

We collect your Personal Information for the primary purpose of providing our services to you and providing information to our clients. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. 

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any Personal Information and non-Personal Information contained in those databases.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

  • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  • With your consent; or where required or authorised by law.

Third parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

  • Third parties where you consent to the use or disclosure; and
  • Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss, and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. 

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Maintaining the quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Website and cookies

When you visit our website [XXX], we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

We may from time to time use cookies on our websites to analyse website traffic and help us provide a better visitor experience. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.

Our websites may also from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Geminate is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

You may wish to participate in social media accounts hosted by us and which we may make available to you on various platforms (such as LinkedIn or Instagram). These platforms are designed to facilitate and share content. We cannot be held responsible if you publicly share Personal Information on these sites that is subsequently used, misused or otherwise appropriated by another party/entity.

Policy updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy, please contact us at: [XXX]

Get in touch with us

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