SMC Privacy Policy

1.1 This is the Privacy Policy (“Privacy Policy”) for Solution Minds Consulting Pty Ltd (ABN 33 618 065 133) (“Solution Minds Consulting”) trading as (“SMC Australia”). This Privacy Policy was last updated in August 2024.

1.2 SMC Australia is committed to protecting your privacy and handling Information you provide.

1.3 Information that you submit to SMC Australia via our website sm-c.com.au, in response to an email request for information, or other outreach from SMC, or as we perform other activities that form part of the operation of our business will be treated in a compliant manner in accordance with this Privacy Policy.

1.4 This Privacy Policy explains how we collect, use, dispose, retention, destroy, and protect your personal information.

1.5 We encourage our website visitors to review this “Privacy Policy” before disclosing any Personal Information.

2.1 When handling Personal Information, we comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth), as well as other applicable legislation, including Australian State and Territory privacy legislation.

2.2 The APPs govern the way in which we collect, use, disclose, store, secure, and dispose of Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

3.1 Personal Information is defined in the Privacy Act 1988 (Cth) to be information or an opinion that identifies an individual. Our main way to collect Personal Information from you is when you fill out forms on our website sm-c.com.au. The information we may collect includes:

• Name
• Email Address
• Phone Number
• Organisation Name
• Job Title
• Any other information you provide.

3.2 We may also obtain Personal Information in many other ways including, but not limited, interviews, contractual engagements, correspondence by telephone, by email, from media and publications, from other publicly available sources, and from third parties.

3.3 We collect your Personal Information for the purpose of:

• Providing our services to you
• Providing information to our third-party advisors and marketing
• For a secondary purpose that is directly related to the primary purpose in circumstances where you would reasonably expect such use or disclosure
• With your consent or where required or authorised by law.

3.4 When we collect Personal Information, we will only, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it in accordance with this Privacy Policy and the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

4.1 We do not typically seek Sensitive Information. Sensitive information is defined in the Privacy Act 1988 (Cth) to include information or opinion about such things as a person’s racial or ethnic origin, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.

4.2 We will obtain explicit consent to collect sensitive information, and it will be used:

• 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.

5.1 We may process the Personal Information data we collect to:

• Respond to your requests for information
• Distribute newsletters, articles, and information updates
• Personalise your experience on our website and deliver relevant content
• To comply with applicable laws, regulations, and legal processes
• To detect, investigate, and prevent fraudulent or illegal activities
• Improve our quality of service
• Facilitate business operations including potential reorganisation, financial transactions, mergers, sales, joint ventures, partnerships, assignments, transfers, or other dispositions of all or any portion of our business and assets.

5.2 On the basis of your consent where required. Insofar as you have granted us consent to the processing of personal information, the lawfulness of such processing is based on your consent. You may withdraw your consent at any time, by making a request to destroy your personal information or de-identify your personal information.

6.1 We may disclose your Personal Information in the following circumstances:

• To trusted third-party service providers who assist us in operating our website, conducting our business operations, or providing services to you
• To comply with legal obligations, lawful requests from government authorities, enforce our policies, or protect our proprietary rights
• With your consent or as otherwise permitted by law.

7.1 We may use web beacons in our emails or on our website to collect information about your interactions with our content. The information collected is to improve our website, services, and communications to you.

8.1 We may use your personal information to send you updates, newsletters, season’s greetings, or other marketing materials. You have the right to opt out of receiving marketing materials at any time by following the opt-out instructions included in each communication, or by contacting us directly at info@sm-c.com.au, and clearly request that we do not send you marketing emails.

9.1 We will retain your Personal Information for as long as necessary to fulfil the purpose for which it was collected. The criteria used to determine our retention periods include:

• Where there is a legal obligation to which we are subject to
• The length of time we have an ongoing relationship with you or provide
  services to you
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations).

9.2 When we deem 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.

10.1 We implement reasonable security measures to protect your personal information from misuse, interference, loss, destruction, unauthorised access, modification, or disclosure. Only authorised employees, contractors, and third parties will have access to any personal information provided by you, and that access is limited by need. All authorised individuals having access to any personal information are obligated to maintain its confidentiality.

10.2 We cannot guarantee that your Personal Information will not become accessible to unauthorised persons, and we are not responsible for any actions resulting from a breach of security when personal information is supplied over the internet or any public computer network.

10.3 In the event of a data breach, we will notify the relevant supervisory authority and inform affected individuals as soon as possible.

11.1 Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites and cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites.

11.2 No links are intended to be nor should be construed as an endorsement of any kind by us of that other website. We encourage you to review the privacy policies of those websites before providing them with any Personal Information.

12.1 We understand the importance of protecting children’s privacy, particularly in their online interactions. Our website is not designed or intentionally targeted at children 15 years of age or younger.

12.2 We do not intentionally collect or store information from anyone under the age of 15. If we become aware that we have collected Personal Information from a child under 15, we will take reasonable steps to delete such information.

13.1 We reserve the right to update or modify this “Privacy Policy” at any time. Any changes will be posted on this page with a revised “effective date”.

14.1 You have the right to request access to, correction, destruction, or de- identification of the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions (please refer to section ‘Retention of Information’).

14.2 If you wish to access your Personal Information or if you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at info@sm-c.com.au.

14.3 In the case of requests that are manifestly unfounded or excessive, particularly due to their repetitive nature, we may:

• Require the payment of reasonable fees that take into account the administrative costs incurred to provide the information, carry out the communications, or take the requested measures
• Refuse to comply with such requests.

14.4 It shall be incumbent upon us to demonstrate the manifestly unfounded or
excessive nature of such requests in the event of the two scenarios above.

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

• Head Office: Level 2, 218 St Georges Terrace, Perth, 6000, Western Australia, Australia
• Email: info@sm-c.com.au
• Telephone: 1800 762 269