Privacy Policy

“Personal information” is information we hold, which is identifiable as being about you, as defined by the Act. This may include “sensitive information” (also defined in the Act).

Sensitive information includes health information such as information about an individual’s physical or mental health, disability or support requirements.

We may collect basic information such as your name, birth date, phone number, postal and residential addresses, and email address when you create an account to enable us to send information, provide updates and allow use of our platform.

We may also collect sensitive information such as disability information and accessibility requirements to the extent it is reasonably necessary for us to tailor our services to meet your needs.

We may ask you directly to provide us personal information.

We may only collect sensitive information about you:

• where you consent;
• when the collection is authorised or required by law; or
• where the collection is otherwise allowed under the Act.

We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

By accessing our website (inclusable.com.au) or our platform, or otherwise transacting with us, you agree to and acknowledge the content of this Privacy Policy. This Privacy Policy is in addition to any terms and conditions or other agreement applicable to our dealings with you.

When you visit our website, we automatically collect certain information (via Google Analytics, Google reCAPTCHA, or similar platforms) about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse our website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to our website, and information about how you interact with our website.

We use cookies to monitor the traffic to the various pages on our website, for statistical and website improvement purposes only. This information is anonymous and will not enable you to be identified. Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to improve your website user experience. You can disable cookies (and applets, or similar) via your computer’s web browser. However, this may restrict access to some webpages and services within our website.

Our website and platform may have links to third party websites (including websites maintained by related entities). These links are provided for your convenience, and we are not responsible for the privacy practices of the websites they lead to. Before using these websites, we recommend reviewing their terms and privacy practices to ensure you are comfortable with them.

We also use Facebook, LinkedIn, Instagram, and other similar service platforms from time to time, and when you communicate with us using these service platforms, we will collect the personal information you provide to those service platforms when engaging with us. Before using these service platforms to communicate with us, we recommend that you also review their terms and privacy practices to ensure you are comfortable with them.

We collect personal information to operate our business and to provide and market our services to you. This includes the following purposes:

• those necessary or incidental to delivering those services;
• managing your customer account;
• tailoring our services to you;
• communicating with you and responding to your enquiries;
• improving our services and customer experience;
• sending you marketing communications (that you can opt out of at any time);
• complying with our legal obligations;
• purposes authorised by law or required to meet our legal obligations; and
• any other purposes disclosed to you or authorised by you, or that you would reasonably expect.

If you provide us with your phone number, email address or any contact details generally, we may contact you directly.

We may disclose your personal information (except for sensitive information) to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy. Personal information (except for sensitive information) is only supplied to a third party when it is required for the delivery of our services.

We will only disclose sensitive information for the primary purpose for which it was collected and in all other circumstances only where you provide your express consent or an exception under the Act applies.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, and in the course of a legal proceeding or in response to a law enforcement agency request.

We use generative artificial intelligence however it does not train on identifiable personal information.

Information that we collect may from time to time may be stored, processed in, or transferred between parties located in countries outside of Australia. When transferring personal information outside Australia within our network, we will comply with the requirements of the Act that relate to transborder data flows. Where the international transfer of personal information is to countries whose privacy laws may be considered not to provide the same level of protection as Australia, our commitment to safeguard your privacy will not change and remains subject to existing obligations and this Privacy Policy.

As part of provision of services to you, we may store your personal information using online or cloud software. The personal information that you provide to us may be transferred to the servers of our software providers as a function of transmission across the internet. By providing your personal information you are consenting to that personal information being transferred to and stored on the servers as set out in this Privacy Policy. However, as the third parties who host our servers do not control and are not permitted to access or use your personal information (except for the limited purpose of storing the information), we do not “disclose” personal information to those server hosts, whether or not they are located overseas.

We advise that some of our server hosts are located overseas.

We will use reasonable endeavours to ensure that our server hosts do not have access to, and use the necessary level of protection to safeguard, your personal information and otherwise comply with the APPs. If you do not want your personal information to be transferred to a server in the location listed in the previous paragraph or to any other international locations, you should not provide us with your personal information or use our services.

We are committed to ensuring that the information you provide to us is secure at all times. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification, and disclosure. We periodically review and update our security measures in light of current technologies. However, the internet is not secure, and we cannot guarantee the security of any information sent to us via the internet, nor can we guarantee that our data storage measures are absolutely secure at all times.

While we take the security of your personal information very seriously, sometimes a data breach can occur. Under the Act, an “Eligible Data Breach” is where there is an unauthorised access or disclosure of, personal information, or loss of personal information that has the potential to cause serious harm to the individual that the data pertains to, and we have not been able to prevent the likely risk of serious harm with remedial action. If we have reasonable grounds to believe that an Eligible Data Breach has occurred, we will notify you and the Office of the Australian Information Commissioner as soon as reasonably possible.

When you create an account with us, we will retain your personal information for our records as permitted by law, unless you request for us to delete this information.

We will destroy personal information in a secure manner or takes steps to de-identify personal information we hold when it is no longer needed or when we are lawfully authorised or required to do so.

You have the right to request access to the personal information we hold about you and to request its correction where it is inaccurate, out of date, or incomplete. We may require you to verify your identity before we communicate with you about your personal information.

We will only refuse to provide you with information that we hold about you where we consider it absolutely necessary, and as permitted by the Act. If we refuse your request for information, we will explain the reasons for our decision in our refusal.

We will deal with all requests to access personal information as quickly as possible, however we may charge a fee for providing access.

You can choose to deal with us anonymously and we will do our best to action any request or complaint that you supply to us. However, without providing your identity, we may be limited in the action that we can take in relation to your enquiry or complaint.

If you have any complaints about our privacy practices, please feel free to contact us. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

For more information about privacy issues in Australia and protecting your privacy, or to make a complaint about our handling of your personal information, you can visit the Office of the Australian Information Commissioner’s website via oaic.gov.au.

For more information about our privacy practices, if you have questions, or if you would like to make a comment or complaint, please contact:

Privacy OfficerInclusable Pty Ltdhello@inclusable.com.au