In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Togram Pty Ltd (ACN 62 642 892 206), whether we are trading as Insync Network Group, Margot Andersen or Talent Insight.

Our Privacy Policy sets out how we collect, use, store and disclose your personal information. Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and electronic or other contact details.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We are committed to maintaining your privacy. You should, however, review our Privacy Policy carefully, and immediately cease accessing or using our website and/or our services if you do not agree to any aspects of our Privacy Policy.

We may change our Privacy Policy from time-to-time by publishing changes to it on our website. All changes are effective immediately upon posting. Your continued use of the website following posting of the revised Privacy Policy means that you accept and agree to the changes. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

1. Collecting information on our website visitors

We collect information on our site visitors collectively including which sections of the site are most frequently visited, how often and for how long. This data is always used as aggregated, non-personal information. We utilise this information to improve and enhance our services by monitoring the areas on the site which are most popular to you. This aggregated information may be shared with our partners to provide them with an overview of how our visitors use the site. This is done for the purposes of providing you with a more efficient site.

We may also use ‘cookies or other similar tracking technologies on our website (like web beacons and social media pixels), that help us track your website and social media usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone, or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our website may not work as intended for you if you do so.

Our web servers may gather your IP address to assist with the diagnosis of problems or support issues with our website. Again, we endeavour to gather this type of diagnostic information in aggregate only so it cannot be traced to an individual user.

2. Collecting information on registered users, members, our clients

As part of registering with us or using our services, we collect personal information about you for you to take full advantage of our services. To do this it may be necessary for you to provide additional information to us as detailed below or as set out in any service registration forms.

We may collect the following types of personal information:

1. identification and contact data: name, age or date of birth, gender, title, mailing or street address, email address, telephone number, username, and other demographic information;
2. financial information: credit card details, account details, payment information;
3. IT information: your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, cookie data and standard web log information;
4. details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
5. any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information, including information you provide to us through filling out forms on our website, surveys, entering queries into our search feature, providing comments or other feedback and via social media; or
6. any other personal information that may be required to facilitate your dealings with us.
7. How do we collect personal information?

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

1. register on our website, download resources from our website and/or purchase services from us;
2. communicates with us through correspondence, chats, email, or when you share information with us from other social applications, services, or websites; or
3. interact with our sites, services, content, and advertising.

If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, live event, or seminar, or purchase any services sold by us on our website, we will automatically enrol you to receive our free email newsletter. If you are in the European Union and opt to receive any of these items, we will only enrol you to receive our free email newsletter if you affirmatively consent to it. If you do not wish to receive our newsletter, you can unsubscribe at any time by using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us at margot@margotandersen.com

4. WHY DO WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION?

We may collect, hold, use and disclose your personal information for the following purposes:

1. to enable you to access and use our website, online courses and any other products and services we may offer from time-to-time;
2. to operate, protect, improve, and optimise our website, online courses, and any other services we provide you with, our business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
3. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
4. to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
5. to administer surveys or promotional activities or events sponsored or managed by us or our business partners; and
6. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information to enable it and us to develop anonymised consumer insights, so that we can better understand your preferences and interests, personalise your experience and enhance the services that you receive.

5. DO WE USE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

We and/or our carefully selected business partners may send you direct marketing communications and information about products and services. This may take the form of emails, SMS, mail, or other forms of communication, in accordance with the Spam Act and the Privacy Act. We may receive a commission from our business partners for doing so. You may opt-out of receiving marketing materials from us by using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us directly at margot@margotandersen.com

6. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may disclose personal information for the purposes described in this Privacy Policy to:

1. our affiliates, employees, consultants, professional advisers, and agents;
2. third party suppliers and service providers (including providers for the operation of our websites and/or our business, or in connection with providing our services to you or when seeking to enforce our Terms or any other agreement between you and us);
3. payment systems operators (e.g. merchants receiving card payments);
4. our existing or potential agents, business partners or partners;
5. our sponsors or promoters of any competition that we conduct via our services;
6. anyone to whom our assets or businesses (or any part of them) are transferred;
7. specific third parties authorised by you to receive information held by us; and/or
8. other persons, including government agencies, regulatory bodies, and law enforcement agencies, or as required, authorised, or permitted by law.
9. DISCLOSURE OF PERSONAL INFORMATION OUTSIDE AUSTRALIA

We may disclose personal information outside of Australia to third party suppliers and cloud providers located in the United States.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

8. Storage & Security of Personal Information

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. This includes using standard security protocols and working only with reputable third-party vendors. However, we cannot guarantee the security of your personal information. Email is not recognised as a secure medium of communication. Credit card information and other sensitive information is never transmitted by us via email.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us about you. However, we will not be held responsible for events arising from unauthorised access of your personal information. You can also play an important role in keeping your personal information secure, by maintaining the confidentiality of any password and accounts used on our sites.

9. Partners & Advertisers

We provide links and/or pass you through to websites operated by third parties. The use of your information by these third-party sites is not within the control of us and we cannot accept responsibility for the conduct of these companies. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

10. GDPR RIGHTS

If you are within the European Union, you are entitled to certain information and have rights under the General Data Protection Regulation (EU) 2016/679 (GDPR). Those rights include:

1. to the extent that you have provided consent to us processing your personal data, you have the right to withdraw that consent at any time, without effecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of that consent;
2. the right to request access to your data that we store, and to either rectify or erase your personal data;
3. the right to object to the processing of your data and to the portability of your data, and to seek restrictions on the processing of your data;
4. the right to lodge a complaint with an authority that has jurisdiction over issues related to GDPR.
5. We will retain any information you choose to provide us until the earlier of:
   1. you asking us to delete the information;
   2. our decision to cease using our existing data providers; or
   3. we decide that the value in retaining the data is outweighed by the costs of retaining it.

We require only the information that is reasonably necessary to agree a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of agreeing a contract with us.

11. CONTACT US

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information, we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

If you think we have breached the Privacy Act or wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take. For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us at margot@margotandersen.com

July 2021