1. PURPOSE

Each entity trading under the name “Carlile Swimming” (“Carlile Swimming”, “we”, “our” or “us”) acknowledges and takes seriously its obligations under the Privacy Act 1988 and is committed to the protection of personal privacy. Carlile Swimming has adopted a set of privacy principles based on the Australian Privacy Principals contained in Schedule 1 of the Privacy Act 1988.

2. POLICY & AMENDMENTS TO POLICY

This policy sets out Carlile Swimming’s privacy protection principles. These are principles that Carlile Swimming has adopted in order to protect information about individuals. These principles deal with the collection, use and disclosure of personal information as well as access to information.

Carlile Swimming may from time to time, review and update this policy to take account new laws and technology or changes to Carlile Swimming’s operations.  All personal information will be governed by its most recent policy posted.

The current version of our privacy policy will be available on our website located at https://www.carlile.com.au/privacy-policy/.

3. WHAT INFORMATION WE COLLECT

We may collect personal information about you or your child (“you” or “your” or “yours”) including your name, mailing address, private address, telephone number, email address, date of birth, history of services received from us and health information (but only to the extent that such health information is reasonably necessary for Carlile Swimming’s functions of activities).  We may also collect credit information about you, which includes identification information, consumer credit liability information, repayment history information, credit rating, the amount of credit, default information, payment information, personal insolvency information and the opinions of other credit providers.

4. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect most personal information directly from you and, where our customers are children, from their parents/guardians. For example, we will collect personal information when you fill in a form of application for swimming lessons or related activities, deal with us over the telephone, send us a letter, an email, communicate with us online or when you visit us in person (including attending a swimming lesson).  We may also collect your information from other Carlile Swimming entities.

5. HOW WE KEEP YOUR INFORMATION

We protect any personal information that we hold about you from misuse or loss. We also protect it from unauthorised access, modification and disclosure. Your personal information can only be accessed by people authorised by us, and for the purpose for which we hold the information. Your personal information may be stored in hard copy documents or electronically in our systems. We maintain physical security, such as locks and security systems, over our paper and electronic data store and premises. We also maintain computer and network security. For example, we use security measures for the internet and other security measures such as identification codes and passwords to control access to computer systems.

6. HOW WE USE PERSONAL INFORMATION

If you do not provide us with certain information, we may not be able to deal with you, or provide you (including your child) with our products and services.  The primary purpose for Carlile Swimming collecting your personal information to administer our services to you (including providing swimming instructions, arranging swimming lessons and maintaining our booking system).  We may also use or disclose personal information we collect about you for other purposes including:

• Helping us to develop and identify products and services that may interest you;
• Telling you about products and services that may interest you;
• Maintaining our relationship with you;
• Conducting market or customer satisfaction research;
• Assisting you in the case of a medical ailment or emergency;
• Helping us develop and maintain a search engine optimisation and advertising presence online;
• Helping us improve or alter the way we manage our booking system and data collection;
• Performing our internal administration and operations including accounting, legal advice, risk management, record keeping, archiving, systems development and testing, credit assessment and staff training; and
• Debt recovery.

7. DISCLOSING TO THIRD PARTIES

We will not disclose your personal information with any third parties without your consent, unless such disclosure is:

(i) required to assist in resolving a health emergency of yours;

(ii) to investigate suspected fraud or unlawful activity;

(iii) for a purpose disclosed in paragraph 6 above;

(iv) to a related Carlile Swimming entity;

(v) for due diligence purposes in respect of any prospective investor in Carlile Swimming or prospective purchaser of the Carlile Swimming business;

(vi) required or authorised by law; or

(vii) for purposes of law enforcement.

The types of third parties we may disclose your personal information to include:

• Emergency services to assist in resolving a health emergency of yours which occurs in connection with a service provided by Carlile Swimming or at a premises where Carile Swimming operates its business;
• Our agents, contractors and external advisers who we engage to carry out our functions and activities from time to time or who assist us to carry out our functions and activities. For example:
  • we may provide names and addresses to a mailing house to mail account statements to you and other customers;
  • we may provide email addresses to our digital marketing agency for purposes of Carlile Swimming’s search engine optimisation and advertising presence;
  • we may provide your personal information to our data analysts and software providers to manage, improve or alter our data collection and booking systems;
  • we may provide your personal information to our lawyers in relation to any legal issue that may arise, or to debt collection agencies to initiate debt collection services;
  • we may provide your personal information to our accountants in relation to any accounting service they are to provide to us.
• Prospective investors in Carlile Swimming or prospective purchasers of Carlile Swimming’s business for due diligence purposes;
• Our related entities, including other Carlile Swimming entities; and
• Regulatory bodies, government agencies, law enforcement bodies, Courts or other parties we are authorised or required by law to disclose information to.

In these situations, we prohibit third parties from using your personal information except for the specific purpose for which we supply it.

You consent to us disclosing your (including your child’s) personal information in the above manner.

8. MARKETING AND PRIVACY

Serving customers well is fundamental to our business. As part of this service we may use personal information we have collected to identify products and services that may benefit you. We may contact you from time to time to tell you about new or existing products or services or special prices available on products or services. You can contact us at any time if you do not want to receive marketing information from Carlile Swimming. We will process these instructions as soon as practical. Carlile Swimming does not disclose names and addresses to third parties for purpose of allowing them to market their products and their services.

9. KEEPING YOUR INFORMATION UP TO DATE

If we have accurate information about you, it enables us to provide you with the best possible service. We take reasonable steps to ensure that your personal information is accurate, complete and up to date at the time of collecting, using or disclosing the information. If you learn that current personal information we hold about you is inaccurate, incomplete or out of date, you should contact us using the contact details below. We will promptly update any personal information that is inaccurate, incomplete or out of date.

10. REQUESTING DETAILS ABOUT YOUR PERSONAL INFORMATION

You can find out what personal information Carlile Swimming holds about you (or your child), subject to exceptions set out in the Privacy Act 1988. You should contact us if you wish to find out about the personal information we hold about you. We will take reasonable steps to verify your identity before giving access. We will normally be able to deal with your request immediately. If the request is complex we will ask you to put the request in writing. We may not be able to tell what personal information we hold about you in certain circumstances including where the law prevents us from disclosing the information.  If we are unable to tell you what personal information we hold about you, we will give the reasons why.

11. ONLINE SECURITY

For your online security your information and online credit card transactions are transmitted through a secure connection using encryption technology. The technology locks all critical information passed from you to us, such as payment information, which is partially encrypted, making it almost impossible for this information to be intercepted. In the event of unauthorised use of your credit card, you must notify your credit card provider in accordance with its reporting rules and procedures.

No credit card details are stored or captured and Carlile Swimming does not see credit card details directly (other than the last 4 digits of your card).

12. CONTACTING US AND HOW TO MAKE A COMPLAINT

You are entitled to complain if you believe that your privacy has been compromised.  If you wish to make a complaint, please send an email or letter to us using the contact details below.

You may also make a complaint to the Office of the Australian Information Commissioner (OAIC) in writing through its online privacy complaint form or by mail, fax or email (subject to certain conditions prescribed by the OAIC).  The OAIC’s contact details are set out at https://www.oaic.gov.au/about-us/contact-us.   We ask that you allow us a period of 30 days to consider and respond to your email or letter of complaint before making a complaint to the OAIC, and that if you do not receive a response from us within 30 days of your email or are dissatisfied with the response, you then take steps to make a complaint to the OAIC should you so wish.

If you wish to make contact with Carlile Swimming concerning your personal information whether it be for access, modification or for complaint you may contact the Privacy Officer as follows:

Manager – Customer Experience

Carlile Swimming
Suite 152, 117 Old Pittwater Road
Brookvale NSW 2100
Phone: (02) 9937 6600
Email: enquiries@carlile.com.au

For further information about Australian privacy issues, visit the Australian Federal Privacy Commissioner’s website: www.privacy.gov.au