We are committed to protecting the privacy of Personal Information provided to us, or otherwise collected by us, offline or online, including through our Site.

In this Privacy Policy:

Site means each of:

our websites (www.startuptoolkit.com.au and www.thriveggp.com); and

our Facebook group (https://www.facebook.com/groups/797628941648131); and

we, us or our means Merivale Developments Pty Ltd 633 749 069 trading as Startup Toolkit or Thrive Governance & Growth Partners (ABN 82 633 749 069).

This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

What is Personal Information and why do we collect it?

“Personal Information” is information or an opinion that identifies an individual. The types of Personal Information we may collect about you include:

your name, images of you and your contact details, including email address, mailing address, street address and/or telephone number;

your age and/or date of birth;

your credit card or payment details;

your demographic information, such as postcode;

information you provide to us through customer surveys;

details of products and services we have provided to you and/or that you have enquired about, and our response to you;

your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;

information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;

additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

any other personal information requested by us and/or provided by you or a third party such as Google or our third party payment processor.

This Personal Information is obtained in many ways including directly from you, via our Site or from third parties and from third parties. We don’t guarantee website links or policy of authorised third parties.

Collection and use of Personal Information

We may collect, hold, use and disclose your Personal Information for the primary purpose of providing our services to you, providing information to our members and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.

In particular, we may collect, hold, use and disclose your Personal Information for the following purposes:

to enable you to access and use our Site, associated applications and associated social media platforms;

to contact and communicate with you;

for internal record keeping and administrative purposes;

for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;

to run competitions and/or offer additional benefits to you;

for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;

to comply with our legal obligations and resolve any disputes that we may have; and

to consider your employment application.

In providing Personal Information to us, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Privacy Policy.

Sensitive Information

“Sensitive Information” is a sub-set of Personal Information and is defined in the Privacy Act 1988 (Cth) to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, sexual orientation or practices, criminal record, health information or biometric information.

Sensitive Information will be used by us only:

for the primary purpose for which it was obtained;

for a secondary purpose that is directly related to the primary purpose; or

with your consent, or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed to:

third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;

our employees, contractors and/or related entities;

our existing or potential agents or business partners;

sponsors or promoters of any competition we run;

anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and

third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.

By providing us with Personal Information, you consent to the disclosure of your Personal Information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with the Privacy Act (Act) and the Australian privacy principles (APPs).

Note the Act and the APPs may not regulate third parties overseas. If any third party engages in any act or practice that contravenes the APPs, it would not be accountable under the Act.

Overseas transfer

Your personal information may be transferred to an overseas jurisdiction with substantially similar data protection laws such as the United States of America, the United Kingdom or countries within the European Union (EU). These countries have data protection laws, which protect personal information in a way that is at least substantially similar to APPs and there will be mechanisms available to you to enforce protection of your personal information under that overseas law.

We do not require the overseas recipients to comply with the APP and we will not be liable for a breach of the APP if your personal information is mishandled.

GDPR

In some circumstances, the European Union General Data Protection (GDPR) provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your personal information is handled in a manner inconsistent with that law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

When 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. However, most of the Personal Information is or will be stored in client files which we will keep for a minimum of 7 years.

Cookies, web beacons and Google analytics

We may use cookies and web beacons on our Site from time to time. While cookies don’t tell us your email address, they do allow third parties, like Google and Facebook, to track you as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

Web beacons monitor your behaviour on our Site and collect data about your web page viewing.

We also use Google Analytics to collect and process data from time to time.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Links to other websites

We do not have any control over Third Party Websites and we are not responsible for the protection and privacy of any personal information that you provide whilst visiting them. Third Party Websites are not governed by this Privacy Policy, even if you followed a link from our website to the Third Party Website.

Policy updates

This Policy may change from time to time and is available on our website (www.startuptoolkit.com.au or www.thriveggp.com).

Complaints and enquiries

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

Name: Anita Brown

Email: support@startuptoolkit.com.au

Last update: January 2024