Effective Date: 15th July 2024
This privacy policy (hereinafter “Privacy Policy”) deals with the protection of your privacy while you use our website, which is hereinafter referred to as “the website” and which is located at www.misso.com.au
The website is owned and operated by: Misso Psychology, Consulting and Therapeutic Services Pty Ltd (ACN 118466989) (hereinafter “we” or “us”)
We are committed to the protection of your privacy while you use the website. We take your privacy very seriously so we urge you to read this policy very carefully because it contains important information about:
- Who we are
- How and why, we collect, store, use and share personal information
- Your rights to your personal information, and
- How to contact us and supervisory authorities in the event that you have a complaint
(1) INTERPRETATION
(a) In this Privacy Policy, unless the context otherwise requires, the following rules of interpretation shall apply:
(I) Words referring to one gender include every other gender.
(II) Words referring to a singular number include the plural, and words referring to a plural include the singular.
(III) Words referring to a person or persons include companies, firms, corporations, organisations and vice versa.
(IV) Headings and titles are included in this Privacy Policy for convenience only and shall not affect the interpretation of this Privacy Policy.
(V) Each Party must, at its own expense, take all reasonable steps and do all that is reasonably necessary to give full effect to this Privacy Policy and the events contemplated by it.
(VI) Any obligation on a Party not to do something includes an obligation not to allow that thing to be done.
(2) WHO WE ARE
Misso Psychology, Consulting and Therapeutic Services Pty Ltd owns this website. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under Australian privacy laws. We may also be regulated by the General Data Protection Regulations (“GDPR”), which apply across the European Union (“EU”), including the United Kingdom (“UK”), and we may be responsible as “controller” of that personal information for the purposes of those laws.
(3) THE INFORMATION WE COLLECT AND USE, HOW WE COLLECT IT, AND WHY WE COLLECT IT
- We collect personal information in a number of ways when you use our website.
- We use your personal information to help us improve your experience with our website.
- This section provides further information about the information we collect, how we collect it, and the purposes for which we collect it.
Personal information you provide to us
(I) We collect the following personal information that you provide to us:
Name
Telephone Number
Email address
Address
(II) We collect this information in the following ways:
When enquiring about any of our services, including counselling, training, supervision, webinars and workshops
(III) We collect this information for the following purposes:
To provide, maintain, protect, and improve our services (including data analytics), to develop new ones, and to protect Misso Psychology Consulting and Therapeutic Services Pty Ltd and its users;
To respond to your submissions, questions, comments, requests, and complaints and provide customer service;
As part of our efforts to keep the information we provide to our users safe and secure;
To protect Misso Psychology, Consulting and Therapeutic Services Pty Ltd rights and or property;
For internal operations, including troubleshooting, data analysis, testing, research, customisation, and improvements to our client services, programs, training and information;
To send you confirmations, updates, security alerts, and support and administrative messages when and if required.
The information collected may be used for other legitimate business purposes. For example, we may use the information to verify your personal information, such as your mobile number, and to contact you for further discussions about our company, the goods and services we provide, and to send information about our company or partners, such as promotions and events. You may receive an email newsletter or other correspondence by providing your email address. Your email address and any personal information will not be shared with third parties unless you have given us consent or for legal or law enforcement reasons.
Cookies and similar technologies
(I) A cookie is a small text file that is placed on your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects (“flash cookies”), and single-pixel gifs. These technologies can be used to track users’ actions and activities and store information about them. We use these cookies and/or similar technologies on this website.
(II) For example we may use cookies to monitor and/or collect the following information:
How many times a user visits the website and pages
Shopping cart log in details
(III) This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
(IV) In addition it should be noted that in some cases our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.
(V) On the first occasion that you use our website we will ask whether you consent to our use of cookies. If you do not, cookies will not be used. Thereafter you can opt-out of using cookies at any time or you can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.
(VI) For further information on cookies generally visit www.oaic.gov.au, www.aboutcookies.org or www.allaboutcookies.org.
(4) WHETHER YOU HAVE TO PROVIDE PERSONAL INFORMATION, AND IF SO WHY
(a) Notwithstanding the preceding clause, you can choose not to provide any personal information to us. However, if you do so, some features of our website may not work as intended.
(5) MARKETING
(a) We would like to send you information about services, seminars, training, professional and personal development workshops, and our business that may be of interest to you. Such information could be sent by post, email, telephone, or text message.
(b) We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up for a newsletter, etc). If you do opt-in to receive such marketing from us, you can opt-out at any time (see “What other rights do you have?” below for further information). If you have any queries about how to opt-out or if you are receiving messages, you do not want, you can contact us using the details provided below.
(6) EMAIL OPT IN/OUT
(a) If you receive an email from us in relation to the website and would prefer not to receive such correspondence in the future, follow the instructions in the email to opt out of future correspondence. You may also contact us using the details at the bottom of this Privacy Policy in order to opt out of future correspondence. We will make all reasonable efforts to comply with your requests promptly. However, you may receive subsequent correspondence from us while your request is being handled.
(7) COMBINING INFORMATION
(a) We do not combine, link or aggregate any of your personal information with other personal information of yours that we are holding.
(8) WHO YOUR INFORMATION MAY BE SHARED WITH
(a) We may share your information with law enforcement agencies in connection with any investigation to help prevent unlawful activity.
(b) We promise not to spam you or to sell or rent your personal information to anyone else.
(9) HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
(a) We will hold your personal information for the following periods:
Name and email address will be kept for as long as the user has an affiliation with, or has subscribed, to Misso Psychology, Consulting and Therapeutic Services Pty Ltd. We will hold your personal information until you have unsubscribed from our services.
(b) Your personal information will be kept, in a form which permits your identification, for no longer than is necessary for the purposes which we have described in this Privacy Policy.
(c) Notwithstanding the preceding sub-clause hereof, your personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes (subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard your rights and freedoms).
(10) REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
(a) We rely on the following as the lawful basis (or bases) on which we collect and use your personal information:
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
- Consent: you have given clear consent to us to process your personal data for a specific purpose.
- Contract: The processing is necessary for a contract we have with you or because you have asked us to take specific steps (such as providing a quote) before entering into a contract.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data, which overrides those legitimate interests. The legitimate interests relied upon are as follows:
The information is necessary for the business to undertake its activities as a counselling, supervision, training and education provider.
(b) We may also rely on the following as the lawful basis (or bases) on which we collect and use your personal information: Consent, Public tasks and consumer interest.
(11) CHILDREN AND THE VALIDITY OF CONSENT
(a) Where we obtain consent from any user, we will take reasonable steps to ascertain whether the user has the legal capacity to give sufficiently informed and valid consent. If we determine that the user does not have legal capacity, parental consent will be required to provide consent for the processing of any personal information.
(12) CONSEQUENCE OF OUR USE OF YOUR PERSONAL INFORMATION
(a) The consequence to you of our use of your personal information is:
- You may be presented with advertisements on our site that may match your locality.
(13) MERGER, RESTRUCTURE OR SALE OF OUR BUSINESS
(a) Part or all of our business may be merged, restructured or sold, including but not limited to through an ordinary sale of business or of stock, a corporate reorganisation, a change in control, bankruptcy or insolvency proceedings.
(b) In the event that such a merger, restructure or sale occurs as described in the preceding sub-clause hereof, we may transfer your personal information, including personally identifiable information, as part of that merger, restructure or sale.
(14) KEEPING YOUR INFORMATION SECURE
(a) By continuing to use the website, you agree to the terms of this Privacy Policy. You acknowledge, agree and accept that no transmission of information or data via the Internet or electronic storage of data is completely secure. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information you provide, and that you transmit such information at your own risk. However, we take the protection and storage of your personal information very seriously.
(b) We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
(c) We will also use technological and organisational measures to keep your information secure. These measures may include the following:
- User account access is controlled by a unique username and password
- All data is stored on secure servers
- Payment details are encrypted using SSL.
(d) We also have procedures for any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
(e) While we will make all reasonable efforts to secure your personal data, you acknowledge that Internet use is not entirely secure when using the site. For this reason, we cannot guarantee the security or integrity of any personal data transferred from you or to you via the Internet. If you have any particular concerns about your information, please contact us using the details below.
(15) TRANSFERS OF YOUR INFORMATION TO OTHER JURISDICTIONS
(a) Our business is based in Australia.
(b) We may need to share some of the information that we collect about you from the UK and the European Economic Area (“EEA”) with organisations both inside and outside Australia. In some cases, we may need to ask you before we do this.
(c) Australia has strict data protection laws, but they differ in some respects from those in the UK and the EEA. In addition, the European Commission has not formally decided that Australia provides an adequate level of data protection similar to that which applies in the UK and EEA.
(d) In addition to handling your information within Australia, your information may be handled in the following countries:
USA, Canada, Israel, India and Asia
(e) We might also store your information in cloud storage or some other form of networked storage. This storage may be accessible from various countries via the Internet, so it is not always practicable to determine the countries where your information might be stored or accessed. If this occurs, then this might mean that your information is disclosed in countries other than those listed above.
(f) Many countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. In addition, the European Commission may not have given a formal decision that the relevant countries provide an adequate level of data protection similar to that which applies in the UK and EEA.
(g) If we transfer, share, store or handle your information outside of the UK or the EEA, it will only be done with relevant protections in place. We will take steps to ensure that your information will be protected in accordance with applicable data protection laws and in accordance with legally recognised data transfer mechanisms, for example:
- Where the European Commission has given a formal decision that the relevant country provides an adequate level of data protection similar to that which applies in the UK and EEA.
- By adopting a European Commission-approved contract, or standard data protection clauses in the form of template transfer clauses adopted by the Commission, that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
- In accordance with a set of European Commission-approved binding corporate rules that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
- Subject to our compliance with an approved code of conduct approved by a supervisory authority that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
- Subject to the terms of our certification under an approved certification mechanism as provided for in the GDPR that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
(h) Any transfers to these countries will be undertaken on the basis that the country, territory or one or more specific sectors in that country or an international organisation ensures an adequate level of protection.
(i) For more information on the basis of any non-EEA transfers, our safeguards or Commission details, please contact us as described below.
(16) ACCESSING, UPDATING AND CORRECTING YOUR PERSONAL INFORMATION
(a) We are committed to ensuring that any of your personal information we hold is accurate and kept up to date.
(b) We will take all reasonable steps to ensure that personal information that is inaccurate (having regard to the purposes for which it was processed) is erased or rectified without delay.
(c) You have the right to request access to any of your personal information which we are holding.
(d) You have the right to request that we update or correct any personal information we hold about you.
(e) In order to request access, an update or a correction to your personal information, you may contact us using the details at the end of this Privacy Policy.
(17) WHAT OTHER RIGHTS DO YOU HAVE?
(a) Under the GDPR, you have a number of important rights, including the rights to:
- Fair processing of information and transparency over how we use your personal information.
- Access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address.
- Require us to correct any mistakes in the information that we hold.
- Require the erasure of personal information concerning you in certain situations (such as if the purpose for which we collected the personal information is no longer necessary or required).
- Receive the personal information concerning you that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations.
- Object at any time to processing of personal information concerning you for direct marketing.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- Object in certain other situations to our continued processing of your personal information.
- Otherwise restrict our processing of your personal information in certain circumstances.
- Claim compensation for damages caused by our breach of any data protection laws.
(b) For further information on each of those rights, including the circumstances in which they apply, refer to the Office of the Australian Information Commissioner (https://www.oaic.gov.au/) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the GDPR (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
(c) If you would like to exercise any of these rights, please:
- Email, call or write to us.
- Provide enough information to identify you.
- Provide us with proof of your identity (a copy of your driving license, passport, or Medicare card.
- Let us know the information to which your request relates
(d) From time to time, we may also offer other methods to unsubscribe (opt-out) from direct marketing, including unsubscribe buttons or web links. If such are offered, please note that there may be a processing period after opting out during which you may still receive marketing materials.
(18) GOVERNING LAW
This Privacy Policy is subject to the laws of Queensland, Australia, and each party accepts the jurisdiction of the courts of Queensland, Australia.
(19) HOW TO COMPLAIN
(a) If you have a complaint in relation to our handling of your personal information, we will endeavour to handle it promptly and fairly. For your information, an overview of our complaints handling procedure is as follows:
(I) Any complaints are forwarded to our complaints officer for review. We aim to review all complaints within seven days of receiving them (although this cannot be guaranteed). If necessary, the complaints officer may then refer the complaint to another section within our organisation for consideration. If further information is required, we may contact you to request that information. If we accept fault in relation to the complaint then we will propose a resolution (which may or may not be the same as any resolution proposed by you). If we do not accept fault, then we will contact you to advise you of this. We aim to complete this entire process within 21 days, provided that we are provided with complete information in the first instance (although this cannot be guaranteed). If you do not provide complete information, this is likely to delay the handling of your complaint.
(II) All complaints must be provided in writing, either by email or regular mail, using the contact details at the end of this Privacy Policy. Describe the nature of your complaint including any relevant dates, people involved, consequences that have occurred, and what you believe should be done to rectify the issue. We will endeavour to respond within 21 days, although we cannot guarantee this.
(III) If you are not satisfied with our response to your complaint, you may refer your complaint to the relevant external dispute resolution organisation in your area.
(IV) The GDPR also gives you the right to lodge a complaint with a supervisory authority, particularly in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Australia is the Office of the Australian Information Commissioner (https://www.oaic.gov.au/), and the supervisory authority in the UK is the Information Commissioner (https://ico.org.uk/concerns/).
(20) CHANGES TO THE PRIVACY POLICY
(a) This Privacy Policy was last updated on 15th July 2024.
(b) We may change this Privacy Policy from time to time. You should check this Privacy Policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website. We will also attempt to notify users of any changes by:
- By email if you have opted to receive emails;
- By a notice on the website header;
- By a notice on the news section of the website.
(21) CONTACT US
(a) If you have any questions about this Privacy Policy or the information we hold about you, please contact us by:
email: [email protected]
Telephone: 07 3342 1838
Mail: PO Box 7041
Holland Park East
Brisbane QLD 4120
(b) Calls will be answered at the following times:
Monday to Friday, 9.00 am – 5.00 pm
Saturday 9.00 am – 1.00 pm
Sunday and Public Holiday – Closed
(c) We may record calls for quality and training purposes.