Privacy - All Tribal Habits Users

This policy applies to all organisations and users of the Tribal Habits software, provided as a subscription service (yourorganisation.tribalhabits.com), customers of the On-Demand Training (purchased at tribalhabits.com/store), or website visitors (at tribalhabits.com).

Version 3.0 – Last updated 18 April 2024

  1. This is Tribal Habits Pty Ltd’s (ABN 74 603 171 820) (we, us or our) privacy policy dated 16 April 2024 which applies to all Users (you or your) of the Tribal Habits Website (Privacy Policy).
  2. This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your information, including any Personal Information.  It applies to use of the Tribal Habits Website, your User Account, if any, and all related sites, applications, services and tools regardless of how you access them.
  3. This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth). In addition to the Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.
  4. This Privacy Policy is available at https://tribalhabits.com/privacy.
 

Definitions and Interpretation

  1. In this Privacy Policy, each of the following terms has the corresponding meaning:

(a) “Associated User” means either an Associated Individual, or an Associated Organisation as the case requires.

(b) “Associated Individual” means an individual User that has been granted access to our Services by an Associated Organisation.

(c) “Associated Organisation” means an organisation User that contracts with us, and grants access to our Services to one or more Associated Individuals.

(d) “Delegate Account” means a User Account issued to a Subscribing Organisation’s delegate to perform a particular function for or on behalf of that organisation, such as administration of other User Accounts associated with that organisation. Any reference to a Subscribing Organisation, whether express or implied, includes an additional reference to each of its Delegate Accounts as the case requires.

(e) “Subscribing Organisation ” means customers that subscribe to our Tribal Habits software as a subscription service, as governed by the terms and conditions located at: https://tribalhabits.com/terms. Any reference to a Subscribing Organisation, whether express or implied, includes an additional reference to each of its Delegate Accounts as the case requires.

(f) “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: (i) whether the information or opinion is true or not; and (ii) whether the information or opinion is recorded in a material form or not.

(g)  “Services” means any services provided by Tribal Habits Pty Ltd accessible through the Tribal Habits Website, as the case requires.

(h) “Security Practices Page” means the page located at https://tribalhabits.com/security/.

(i)  “Tribal Habits Website” means the software platform offered by Tribal Habits Pty Ltd through https://tribalhabits.com, or any other domain through which you request or receive services from us.

(j)  “Terms and Conditions” means the terms and conditions, or any of them, which apply to our provision of Services, or any of them, to you.

(k) “User” means a user of the Tribal Habits Website including without limitation any person or entity that:

(i) views the Tribal Habits Website in a browser;

(ii) submits any information to an User Account;

(iii) submits any information to the Tribal Habits Website, through use of an enquiry form, or otherwise;

(iv) signs up for an account with the Tribal Habits Website;

(v) contracts for payment for Services using the Tribal Habits Website;

(vi) conducts any other type of transaction on the Tribal Habits Website; or

(vii) accept any Services from us..

(l) “User Account” means a User account on the Tribal Habits Website that has user credentials such as a login and password, and includes any Delegate Accounts.

Parties bound

  1. You accept this Privacy Policy when you sign up for a User Account, access the Tribal Habits Website, or otherwise accept our Services.
  2. We may amend this Privacy Policy at any time by posting a revised version on the Tribal Habits Website. The revised version will be effective as follows:

(a) for any User registering for the first time, the revised version will apply immediately; and

(b) for any existing User the revised version will apply 7 days after it being posted on the Tribal Habits Website. 

As an existing User, if you continue to use the Tribal Habits Website after those changes are in effect, you agree to the revised policy. For the avoidance of doubt, the current version of the Privacy Policy will remain in effect until the revised version takes effect. You are responsible for determining the suitability of the Privacy Policy in force from time to time for your particular purposes. After the revised version has been posted, you may obtain a copy of the previous version by contacting us at the details provided at the end of this Privacy Policy.

How we collect information

  1. We collect information in a variety of ways, including

(a) When you provide it directly to us:

(i)  sent to us by your computer, mobile phone, or other access device when you:

  1. navigate to the Domain, or any related pages with web browser;
  2. submit any information using an enquiry form or by any other method provided on the Tribal Habits Website;
  3. access a User Account; or
  4. otherwise use the Tribal Habits Website to obtain Services from us.

(b) when you use any website we operate (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);

(c) from third parties, such as your employer; or

(d) from publicly available sources.

Information that we collect

  1. The types of personal information we may collect about you includes:

(e) Identity Data including your name.

(f) Contact Data including your telephone number, address and email.

(g) Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).

(h) Transaction Data including details about payments to you from us relating to your User Account and from you to us and other details of products and services you have purchased from us or we have purchased from you.

(i) Technical and Usage Data when you access the Tribal Habits Website, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies), and communications with our website.

 (j) Profile Data including your username and password for your User Account, profile picture, purchases or orders you have made with us, content you post, send receive and share through our website, information you have shared with our social media platforms, and support requests you have made.

(k) Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.

(l) Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

(m) Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

(n) Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We will not actively request Sensitive Information.

  1. A Subscribing Organisation that uses our Website or portal may request additional information about you than what is described above, including Sensitive Information. We do not use, exploit or access this information. We will hold this information in accordance with the Australian Privacy Principles and this Privacy Policy. If, for any reason, we need to access or use this additional data or information, we will notify you of our access/use.
 

Our disclosures of personal information to third parties

  1. Personal information: We will only disclose personal information (excluding sensitive information) to third parties where:

i. it is necessary as part of our business; or

ii. where we have your consent; or

iii. where permitted by law.

This means that we may disclose personal information (excluding sensitive information) to:

(a) our employees, contractors and/or related entities;

(b) IT service providers, data storage, web-hosting and server providers;

(c) marketing or advertising providers;

(d) professional advisors, bankers, auditors, our insurers and insurance brokers;

(e) payment systems operators or processors; 

(f) our existing or potential agents or business partners;

(g) sponsors or promoters of any promotions or competition we run;

(h) if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

(i) courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

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

(k) third parties to collect and process data, such as analytics providers and cookies; and

(l) any other third parties as required or permitted by law, such as where we receive a subpoena.

How we use Cookies

  1. When you access your User Account or use the Tribal Habits Website, we may place small data files on your computer, or other device.  These data files may be cookies, pixel tags, or other local storage provided by your browser or associated applications (collectively “Cookies”).  We use Cookies to:

(a) identify and authenticate you as a User;

(b) enable functionality on and to customise the Tribal Habits Website and related content;

(c)  measure promotional effectiveness; 

(d)  mitigate risk and prevent fraud; and

(e)  to promote trust and safety with our Users’ and the Tribal Habits Website.

    1. We may use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your User Account or close your browser. Persistent Cookies remain on your browser until you erase them or they expire.
    2. You can find more information about the individual cookies we use, their category, where they are used (on our marketing website or within the Tribal Habits application) and the purposes for which we use them in the table below:

CookieCategoryUsedPurpose
rc::a rc::cNecessaryMarketing website (tribalhabits.com)This cookie is set by the Google reCAPTCHA service to identify bots to protect the website against malicious spam attacks.
_ga_*AnalyticsMarketing website (tribalhabits.com)Google Analytics sets this cookie to store and count page views.
_gaAnalyticsMarketing website (tribalhabits.com)Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.
sbjs_sessionAnalyticsMarketing website (tribalhabits.com)Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.
__hstcAnalyticsMarketing website (tribalhabits.com)Hubspot set this main cookie for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit),
and session number (increments for each subsequent session).
hubspotutkAnalyticsMarketing website (tribalhabits.com)HubSpot sets this cookie to keep track of the visitors to the website. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.
messagesUtkFunctionalMarketing website (tribalhabits.com)HubSpot sets this cookie to recognize visitors who chat via the chatflows tool.
__stripe_mid __stripe_sidNecessaryMarketing website (tribalhabits.com)Stripe sets this cookie to process payments.
CookieLawInfoConsent cookielawinfo-checkbox-necessaryNecessaryMarketing website (tribalhabits.com)CookieYes sets this cookie to record the default button state of the corresponding category and the status of CCPA. It works 
only in coordination with the primary cookie.
elementorNecessaryMarketing website (tribalhabits.com)The website’s WordPress theme uses this cookie. It allows the website owner to implement or change the website’s content in real-time.
_vue-tribe_sessionFunctionalIn application (*.tribalhabits.com)Created for all users. Required to authenticate the user and their session.
AWSALBFunctionalIn application (*.tribalhabits.com)Created for all users. Required to maintain user session within the AWS Application Load Balancer.
AWSALBCORSFunctionalIn application (*.tribalhabits.com)Created for all users. Required to maintain user session within the AWS Application Load Balancer.
intercom-id-[app_id]FunctionalIn application (*.tribalhabits.com)Only created for admins within the Tribal Habits app. Used by intercom.com integration. Anonymous visitor identifier cookie.
intercom-session-FunctionalIn application (*.tribalhabits.com)Only created for admins within the Tribal Habits app. Used by intercom.com integration. Identifier for each unique browser session. This session cookie is refreshed on each successful logged-in ping, extending it one week from that moment.
intercom-id-[app_id]FunctionalIn application (*.tribalhabits.com)Only created for admins within the Tribal Habits app. Used by intercom.com integration. Identifier for each unique device that interacts with the Messenger. It is refreshed on each successful ping, extending it another 9 months.
  1. We may encode our Cookies so that we can interpret the information stored in them. You are free to decline our Cookies if your browser or browser add-on permits, but doing so will interfere with, and may prevent you from using your User Account or the Tribal Habits Website.
  2. You may encounter Cookies on websites that we do not control. For example, if you access a third party website through your User Account, there may be a Cookie placed by the web page or an application within it.
  3. We use third parties like Google Analytics for website analytics. You may opt-out of cookies from Google Analytics on their respective websites. We do not currently recognise or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
 

How we protect and store Personal Information

  1. Throughout this Privacy Policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider Personal Information to include information that has been made anonymous and does not identify a specific individual User. Please note that organisations do not have “Personal Information”, and any reference to “Personal Information” relates solely to information about and belonging to individuals.
  2. Nothing in this Privacy Policy is to be read as limiting how we may use de-identified or anonymous data.
  3. We store and process your Personal Information on our computers in Australia and other locations around the world including the United States of America. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse and unauthorised access, disclosure and alteration.
 

Security

  1. We use reasonable steps to protect information you provide to us from loss, misuse, and unauthorised access or disclosure while in transit, during processing, and while at rest (being stored).
  2. We encrypt the transmission of data through public networks using secure socket layer technology (SSL).
  3. Nothing in this Privacy Policy or the Security Practices Page is to be interpreted as a warranty or guarantee about the security of your information, it is merely a description of the measures that we take to secure data from time to time. And, by submitting any information to us you acknowledge that no electronic or email transmission or digital storage mechanism is ever fully secure or error free.
  4. To learn more about current practices and policies regarding security and confidentiality, please see our Security Practices Page; we keep that document updated as these practices evolve over time.
 

Associated Users

  1. In relation to Associated Users, in addition to anything else described in this Privacy Policy:

(a) Any User associated with a domain controlled by any one of our Subscribing Organisations is deemed an Associated Individual for the purposes of this Privacy Policy. By creating an account under a Subscribing Organisation’s portal, Users agree to the Subscribing Organisation having full access to their data in accordance with this Privacy Policy. It is the responsibility of the Subscribing Organisation to accept this Privacy Policy on behalf of Associated Individuals.

(b) As an Associated Individual:

i. you authorise us to share your name, email address, User Account identifiers and usage data with the relevant Associated Organisation;

ii. if you communicate with us to resolve a technical or account problem, if we deem necessary you authorised us to discuss the issue with the relevant Associated Organisation;

iii. if you upload information to the Tribal Habits Website, you authorise us to disclose some or all of that information to the relevant Associated Organisation, and you acknowledge that the Associated Organisation may have the right to take ownership of that information (subject to any agreement to the contrary that you have with that Associated Organisation), and that we may deal with the Associated Organisation accordingly; and

iv. you acknowledge that this Privacy Policy does not govern the collection, use, storage, or retention of your information by the relevant Associated Organisation, which may be subject to other agreements, policies and arrangements with that organisation – please contact the relevant Associated Organisation directly in relation to this issue.

(c) as an Associated Organisation you authorise us:

i. to associated any information we collect under clause (b) with your User Account; and

ii. disclose any such information to each of your Delegate Account holders as the case requires.

Marketing

  1. We do not sell or rent your Personal Information to third parties for their marketing purposes. This clause 30 is subject to clause 33.
  2. We may combine your information with information we collect from other companies and use it to improve and personalise the Tribal Habits Website, content, and advertising.
  3. If you do not wish to receive marketing communication from us, outside of the Tribal Habits Website then you may opt-out at any time by using the unsubscribe or opt-out feature contained in the communication that we send to you.
  4. To the extent that we offer third party services on the Tribal Habits Website, and you subscribe for, purchase, or request such third party services, you authorise us to share your information, including Personal Information, with that third party, and acknowledge that we do not limit such third parties’ use of your information, including its marketing purposes. You further acknowledge that we have no control over that third party’s information practices, or the manner in which that third party uses your information.
 

System related communication

  1. You cannot opt-out of system messages that relate to your User Account and use of the Tribal Habits Website.

No limit on use of your data for analysis and development of our systems and Services

  1. Information generated by the Tribal Habits Website, which includes data relating to your use of the Tribal Habits Website, is used by us for our internal development purposes, and nothing in this Privacy Policy is to be read as limiting our right to use that information to analyse usage, and develop our systems and Services.
  2. Unless specifically described otherwise in this Privacy Policy or disclosed to you prior to purchasing any particular Services, Tribal Habits Pty Ltd will not sell or rent any of your Personal Information to third parties for their marketing purposes without your permission, and will only share your Personal Information with third parties as described in this Privacy Policy.
  3. If you create an account, take membership on, or transact directly on a third party website or via a third party application, any information that you enter on that website or application will likely be shared with the owner of that website or application. These sites are governed by their own privacy policies and terms and conditions and you are encouraged to review their privacy policies before providing them with Personal Information. Tribal Habits Pty Ltd is not responsible for the content or information practices of third parties.
 

How you can access or change your Personal Information

  1. You can review and edit your Personal Information by logging into the Tribal Habits Website profile settings page; or otherwise by contacting our Privacy Officer at [email protected].
  2. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
 

How you can contact us about privacy questions

  1. If you have questions or concerns regarding this Privacy Policy, you should contact us by email at [email protected]. If you have a privacy complaint, you should report it by either:

(a)  emailing us at [email protected]; or

(b) at our address for notices: 1006 / 241 Adelaide Street, Brisbane, QLD, 4000.

 

Handling your complaints

  1. We aim to:

(a) Acknowledge receipt of all complaints within 5 business days; and

(b) Resolve all complaints within 60 days, however, this may not be possible in all circumstances.

  1. Where we cannot resolve a complaint within 60 days, we will notify you of the reason for the delay as well as an indication of when we expect to resolve the complaint.

 

APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose of use / disclosure Type of DataLegal Basis for processing
To do business with you.• Identity Data
• Contact Data
• Performance of a contract with you
To contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us.• Identity Data
• Contact Data
• Profile Data
• Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.• Identity Data
• Contact Data
• Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions
For internal record keeping, administrative, invoicing and billing purposes.• Identity Data
• Contact Data
• Financial Data
• Transaction Data
• Performance of a contract with you
• To comply with a legal obligation
• Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points
For analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms.• Profile Data
• Technical and Usage Data
• Legitimate interests: to keep our website updated and relevant, to develop our business, improve our business and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.• Identity Data
• Contact Data
• Technical and Usage Data
• Profile Data
• Marketing and Communications Data
• Legitimate interests: to develop and grow our business
To run promotions, competitions and/or offer additional benefits to you.• Identity Data
• Contact Data
• Profile Data
• Interaction Data
• Marketing and Communications Data
• Legitimate interests: to facilitate engagement with our business and grow our business
If you have applied for employment with us, to consider your employment application.• Identity Data
• Contact Data
• Professional Data
• Legitimate interests: to consider your employment application
To comply with our legal obligations or if otherwise required or authorised by law. • To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.

Data Transfers

The privacy protections available in the countries to which we send data for the purposes listed above may be less comprehensive than what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes: 

• only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or 

• including standard contractual clauses in our agreements with third parties that are overseas.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation. If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.

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