Privacy Policy

 

Last updated: January 2016

About us

This Privacy Policy explains what information 2BA Pty Ltd ACN 610 305 292 and its related entities (together referred to as 2BA) collect about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services. It applies to all products and services provided by 2BA (2BA Services), including but not limited to the provision of specialised golf training and technique advice from professional golf coaches.

By using 2BA Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Commitment to protecting privacy

Privacy concerns are important to us.

It is 2BA’s policy to comply with the Australian Privacy Principles (Principles), as set out in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy is incorporated into, and subject to, the Terms and Conditions applicable to the 2BA Service provided to you. Your use of 2BA Services and any information you provide remain subject to the terms of this Privacy Policy and the applicable 2BA Terms and Conditions.

Where our services contain links to third-party websites, these sites are governed by their own privacy statements. 2BA is not responsible for their operation, including but not limited to their information privacy practices.

Types of information collected

When you use our services, we collect information about you, including personal information. Personal information is information that may be used to readily identify or contact you as an individual person, such as: your name, date of birth, gender, current and previous addresses, telephone or mobile numbers, email addresses, user names, and geographic information.

We only collect personal information that is necessary for the function and activities of our business and the provision of 2BA Services. We may also ask you to provide credit card or other payment information in order to process payment for your 2BA Service.

Collection from third parties

Where it is reasonable and practicable to do so, we will collect personal information about you only from you. We may sometimes be provided with information about you from a third party, such as a social networking site, or other site through which you have used our services. We will typically only do this with your consent.

Passive collection

When you visit our website, our server attaches a small data file called a "cookie" to your computer’s memory.

Cookies are pieces of information that may be transferred to your computer’s memory when you visit a website for record keeping purposes. Most web browsers are set to accept cookies. However, if you do not wish to receive any cookies you may set your web browser to refuse cookies. We use cookies to provide us with anonymous information on the use of our website and mobile application and to know what you find interesting on our website and mobile application. We do not link this information back to your identity or other information that you have provided to us. We do not store any information that identifies you inside cookies.

Purpose of collection

The primary purpose for collecting information is to enable 2BA to better provide you with the 2BA Services, in a manner tailored to you. We may also use the information collected for other secondary purposes related to this primary purpose.

Consequences of not providing information

If you choose not to supply certain personal information, we may not be able to provide you with the level of service or the services you require.

General uses of information

Some of the specific purposes for which we use the information we collect about you (including personal information to the extent applicable) include to:

  •  Provide, operate, maintain, improve, and promote 2BA Services;
  • Communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about services; providing other news or information about us; and sending you technical notices, updates, security alerts, and support and administrative messages;
  •  Enable you to access and use the 2BA Services;
  •  Inform golf coaches and professionals of your contact details and training requirements;
  • 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; and
  •  For other purposes about which we notify you.

Use of aggregated data

We also may use the information we collect about you in an aggregate form.

Aggregate data is information (originally personally identifiable or non-personally identifiable) that subsequently is used in aggregate form.

Although aggregate data may be based in part on personally identifiable information about you, it does not identify you personally. We may use aggregate data we collect in order to conduct analysis or research, such as research about customer demographics, internet use, and interests and behaviour. We may share this type of aggregate data with a variety of third parties, including our affiliates, advertisers and other current and prospective business partners. As this form of data does not identify particular users, these third parties will not be able to contact you based solely on this data.

Aggregate data may also be used for website administration, advertising, and promotional purposes, and we may share this information with various affiliated and unaffiliated entities. We may also enter into agreements with outside companies that possess the technology that allows us to customise the advertising and marketing messages you receive while using the 2BA Services. Your non-personally identifiable information and clickstream data about your activities may be shared with these companies so this customisation can be accomplished. Our agreement with these companies restricts them from sharing your information with third parties or using it for any other purpose. Clickstream and demographic information may also be shared with our advertisers and business partners.

2BA may provide targeted advertisements based on information about you, such as your interests. 2BA does not provide any personally identifiable information to the advertiser when you interact with or view a targeted ad, although advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria.

Disclosure of information

We may disclose your information to third parties who provide services to us, including organisations and contractors that assist us with the purposes for which we use your information. These services include:

  • customer enquiries;
  • operations, billing and debt-recovery functions;
  • information technology and network services;
  •  market research and marketing services.
  • We may also disclose your information:
  • to your authorised representatives or advisors, or when you ask us to do so;
  • to credit-reporting bodies and fraud-checking agencies, and to credit providers for credit related purposes such as credit-worthiness, credit rating, credit provision and financing;
  • our related entities or our business partners;
  • to organisations as required or authorised by law;
  • to law enforcement and national security agencies, and other government and regulatory authorities as required or authorised by law;
  • to third parties who assist us to manage or develop our business and corporate strategies and functions;
  • for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business; and
  • to our contractors, consultants and service providers.

Direct marketing

We and/or our carefully selected business partners may send you direct marketing communications and information about our 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. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

Protection and transmission of data

We may disclose your information to our hosting service providers or other service providers in Australia or any other country in which we may conduct our business from time to time. Where practicable, we will inform you about where your information is sent.

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.

We expect our employees and contractors who handle personal information to comply with the Privacy Act and will take appropriate action in response to breaches of the obligations imposed by the Principles.

We will ensure that all reasonable steps are taken to protect all personal information from misuse, interference, loss and unauthorised access, modification and disclosure. Although we seek to engage external service providers who also comply with these requirements, no security system is impenetrable and we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Accordingly, and to the extent permitted by law, we do not accept responsibility for the misuse of personal information while stored on our systems or otherwise in our care or in the care of our external service providers.

Access to information

You have a right to access your personal information held by us. We will take reasonable steps to correct any information you establish is not accurate, complete and up-to-date. To request access to any personal information we hold about you, contact us in writing via our contact details at the end of this Privacy Policy. All requests will be responded to within a reasonable period. To access any information we hold we will require you to verify your identity, and specify what information you require access to.

We reserve the right to refuse access to your personal information if providing access would be unlawful or would have an unreasonable impact upon the privacy of other individuals.

If you have subscribed to any of our newsletters or subscriptions, or are receiving promotional communications, and no longer wish to receive such communications, you may opt out of receiving them at any time by clicking the “unsubscribe” button on any email communications that we send you or by contacting us at the details set out below.

Disposal of information

We will take reasonable steps to destroy or de-identify personal information if it is no longer needed for any purpose for which it may be used or disclosed or if we are no longer required to retain the information at law.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the ‘Last Updated’ date at the top of this Privacy Policy and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to our website or sending you an email notification). We encourage you to review our Privacy Policy whenever you access our website to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you must stop using 2BA Services.

Complaints about an interference with privacy

If you consider that any action we take breaches this Privacy Policy or the Principles, you can make a complaint by contacting us at the address set out below. We will endeavour to act promptly in response to a complaint.

Contact

For further information, or if you have any questions, comments, or concerns about any of the provisions of this Privacy Policy, please contact us:

Attn: Compliance Officer

2BA Pty Ltd
201/33 Cliveden Close

JOLIMONT VIC 3002

AUSTRALIA