Privacy Policy

1 DEFINED TERMS

1. Clause 1 defines the terms used in this policy, and other terms are described elsewhere in this policy.
2. Collect includes holding or storing the following collection.
3. Disclose may include to transfer.
4. Health Information is Personal Information about you that is collected concerning health service (if any) that you receive from one of our customers, including information about your health, organ donation intentions, genetic attributes and the health services supplied or supplied to you.
5. Health Reasons means any of the following:
   • Collection of Health Information if necessary to provide a health service to the relevant individual (who may be you) and the group is required or authorised by or under Australian law, or the information is collected under rules established by competent health or medical bodies that deal with obligations of professional confidentiality which bind the organisation (Professional Health Rules).
   • Collection of Health Information if: (a) necessary for research relevant to public health or safety, the compilation or analysis of statistics relevant to public health or safety, or the management, funding or monitoring of a health service; and (b) de-identified information would not be adequate for that purpose, and (c) it is impracticable to obtain the individual's consent; and (d) the collection is required by or under an Australian law or the information is collected under Professional Health Rules or an approved APP guideline.
   • Use or disclosure of Health Information if: (a) the use or disclosure is necessary for research or the compilation or analysis of statistics relevant to public health or safety, and (b) it is impracticable to obtain the individual's (c) it is conducted under an approved APP guideline, and (d) in the case of disclosure – it is reasonably believed that the recipient of the information will not disclose the information.
   • Use or disclosure of genetic information if (a) the information was obtained in the course of providing a health service to an individual; and (b) it is reasonably believed that the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of another individual who is a genetic relative of the first individual; and (c) the use or disclosure is conducted in accordance an approved APP guideline, and (d) in the case of disclosure – the recipient of the information is a genetic relative of the first individual.
   • Disclosure of Health Information if: (a) a health service is provided to the individual, (b) the recipient of the information is a responsible person for the individual, and (c) the individual is physically or legally incapable of giving consent to the disclosure or physically cannot communicate consent to the disclosure, and (d) another individual (the carer) providing the health service is satisfied that either the disclosure is necessary to provide appropriate care or treatment of the individual or) the disclosure is made for compassionate reasons; and (e) the disclosure is not contrary to any wish expressed by the individual before the individual became unable to give or communicate consent and of which the carer is aware, or of which the carer could reasonably be expected to be aware; and (f) the disclosure is limited to the extent reasonable and necessary for a purpose mentioned in sub-item (d) above.
6. Legal Reasons means any of the following:
   • It is unreasonable or impracticable to obtain your or the individual collection, use or disclosure of Personal Information is necessary to lessen or prevent a serious threat to an individual's safety or a serious threat to public health or safety.
   • We believe the collection, use or disclosure of Personal Information is necessary for us to take appropriate action if we have reason to suspect unlawful activity or serious misconduct concerning our functions or activities have been or are being engaged in.
   • The collection, use or disclosure of the Personal Information is required or authorised by or under an Australian law or a court/tribunal order.
   • The collection, use or disclosure of the Personal Information is reasonably necessary to establish, exercise or defend a legal or equitable claim.
   • The collection, use or disclosure of the Personal Information is reasonably necessary for a confidential alternative dispute resolution process.
   • We reasonably believe that the use or disclosure of Personal Information is necessary for enforcement-related activities by an enforcement body.
7. Personal information is information about an identified or reasonably identifiable individual, including Sensitive Information.
8. Sensitive Information is Health Information or Personal Information of a sensitive nature, such as information about race, ethnicity, political opinion, religious beliefs or sexuality.
9. Use may include to disclose or transfer.
10. We means Pioneera Group Pty Ltd (ACN 623 994 230).
11. You means the individual reading this policy if that individual is also an individual about whom we must, under the Privacy Act 1988 (Cth), abide by this policy.

COLLECTION

2.1 Collection

1. We collect Personal Information about you:
• when you provide it to us in the course of completing information fields (e.g. name, email address, phone number);
• when you other provide it to us when using the website or our services; and
• about your IP address or cookies in the course of using the website.
2. We collect the following kinds of information about you, which may be Personal Information:
• Name, email and other personal details relating to your employment
• Language and behaviour as used in the workplace and
• cookies (if you enable them.
3. We hold your Personal Information on internet servers operated by hosting service providers and have entered into service agreements with those service providers.

2.2 Reasons

1. We collect only the personal information we need to collect to supply our services. To the extent (if any) that the Personal Information is Sensitive Information, we will not collect that information without your consent. To the extent that we do not need to collect Personal Information about you, you are not obliged to provide that information to us.
2. Specifically, we collect Personal Information (as relevant):
• to enter into contractual relations with you, e.g. our website terms and conditions;
• to supply our services to you;
• to enable you to use the website and any goods we may provide;
• to assist us in improving our services;
• for Legal Reasons (as applicable); and
• to otherwise comply with our obligations under the law.
3. If you do not enable or permit us to collect this Personal Information, then we may not be able to do all of the things set out in paragraph (b).

2.3 Collecting entity

The entity collecting Personal Information is Pioneera Group Pty Ltd (ACN 623 994 230) of 2/9 Rosemont Ave, Woollahra NSW 2025.

3 USE OF PERSONAL INFORMATION

1. We use Personal Information to supply our services to you and to send you communications about these matters, such as administrative notices.
2. If you provide your name and mobile phone number or email address to us, you thereby consent to our using your Personal Information to market our services to you, such as by adding you to our mailing list and notifying you of promotional offers. You may withdraw this consent at any time at no cost. All our direct marketing communications will include an unsubscribe or other opt-out mechanism. If you provide your IP address or cookies to us, you also consent to use that Personal Information about you to market services by displaying targeted banners or similar. You have control over whether you provide cookies or an IP address to us. We will not use your Sensitive Information (if any) for direct marketing without your consent.
3. (c) We may also use Personal Information for compiling general information that is not itself Personal Information (General Information). General Information may include aggregated statistical information about your attributes, interests and activities. We may use General Information to, among other things, better understand our clients' needs and improve our services.
4. We may use your Personal Information for Health Reasons, Legal Reasons or to the extent that to store your Personal Information is to use it.

4 DISCLOSURE & TRANSFER OVERSEAS

4.1 Disclosure by us

1. We may disclose your Personal Information only to sub-contractors supplying us with their services so that those parties can provide their services to us, enabling us, in turn, to supply our services to our customers and, in turn, their services to you.
2. We will not disclose your Personal Information to any third party for direct marketing purposes.
3. We may disclose your Personal Information for Health Reasons or Legal Reasons.
4. We may disclose General Information to any person for any commercial purpose.

4.2 Transfer overseas

1. Subject to clause 4.1, we may transfer your Personal Information to a person or organisation in a foreign country, but only if one of the following applies:
• if we provide the Personal Information to a service provider located overseas for the limited purpose of storing and managing the Personal Information, our contract with the provider: (a) obliges the provider not to use or disclose the Personal Information unless storing and managing the information; (b) obliges any of the provider's to agree to the same obligations, and (c) gives us effective control of the information;
• we have taken such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Overseas Compliance);
• we reasonably believe that the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to how the APPs protect the information, and there are mechanisms that you or the relevant individual can access to take action to enforce that protection of the law or binding scheme;
• we tell you that Overseas Compliance will not apply, and you consent to the transfer; or
• the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order.

5 ACCESS

1. You can access Personal Information about yourself by contacting us or logging into your account with our relevant customer (if applicable). If we are to provide access to the information, we will do so within a reasonable time.
2. Notwithstanding paragraph (a), we may not grant you access to Personal Information for reasons including:
• if doing so would have an unreasonable impact on the privacy of other individuals;
• if the request for access is frivolous or vexatious; or
• for Health Reasons, Legal Reasons or similar reasons.
3. We will provide reasons for our decision if we deny you access to Personal Information.

6 INTEGRITY & SECURITY

6.1 Integrity

1. We will take reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete, up-to-date, relevant and not misleading (together, satisfactory).
2. If you believe that the Personal Information we hold is unsatisfactory, you may contact us and ask us to correct the information.
3. If you demonstrate that Personal Information held by us is not satisfactory, we will, within a reasonable time, take reasonable steps to correct the information. If you claim that such information is not satisfactory and we disagree, we will notify you of our reasons and, at your request, accompany the information with a note stating your position about the information.
4. If we correct information that was not satisfactory and previously disclosed to a third party, we will take reasonable steps to notify that third party.

6.2 Security

We will take reasonable steps to protect Personal Information from misuse, loss, unauthorised access, modification or disclosure.

7 DISPOSAL

1. We will take reasonable steps to destroy, disable access to or permanently de-identify Personal Information if we no longer need it for any purpose for which we would be permitted to use or disclose the information under the APPs.
2. However, characteristics of information storage technology mean that it is not reasonably possible to delete every last remnant of information we have collected.

8 COMPLAINTS

1. If you wish to complain about a potential breach of the APPs by us, please write to us at:

   Pioneera Group Pty Ltd (ACN 623 994 230)
   2/9 Rosemont Ave
   Woollahra NSW
   Australia 2025
   Email: hello@pioneera.com

1. If we receive a complaint from you, we will handle the complaint in the following way:
   • We will acknowledge receipt of your complaint, and we will investigate your complaint.
   • We will notify you of the outcome of our investigation.
   • We will provide you with basic information about further action you may take if you are dissatisfied with the outcome of our investigation.

9 THIS POLICY

9.1 Variation

We may vary this policy at any time by amending the version of this document accessible by you on a webpage on our website.

9.2 Principles of interpretation of this policy

1. In this policy, unless expressly to the contrary and as appropriate in the context:
   • an expression in the plural may be read in the singular, and vice versa;
   • a reference to a thing or things includes a reference to any, some or all, or part or whole, of the thing or things;
   • a reference to an act includes an omission and to the causing to be done of that act or omission;
   • a reference to a person doing an act includes a reference to the doing of the act on behalf of the person;
   • a reference to one alternative does not, of itself, exclude any other option;
   • an expression of the exercise of a right means the exercise of that right at the sole and absolute discretion of the relevant party;
   • a list of rights is not to be read as an exhaustive list of rights;
   • nothing in this policy is an admission by us that, merely by hosting customer data that includes Personal Information, we are 'collecting that Personal Information or that Personal Information is being 'disclosed to" us, within'the meaning of Australian privacy law; and
   • a reference to a provision, clause or paragraph is a reference to a condition, clause or section of this policy.