Privacy Policy

About this Privacy Policy

West Hoxton Childcare Pty Ltd (referred to as Clever Cookies, we, us orour) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information.

Clever Cookies, from time to time, is related to other companies and entities (related entities) including some which have only partially common ownership. This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Clever Cookies, we, us or our is also a reference to those related entities.

Collection of your Personal Information

When referring to “Personal Information”, we mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. Your name, address and phone number are examples of personal information. The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

(a) name;
(b) age and/or date of birth;
(c) contact details including telephone numbers (landline and/or mobile);
(d) current and previous address (including postal address);
(e) email address;
(f) gender;
(g) payment details, such as your credit card or bank account details;
(h) occupation and employment details including employment status and any previous work experience;
(i) information from or in connection with your resume or job application if you apply for a position with us;
(j) geographical location;
(k) Australian Business Number (ABN);
(l) dietary requirements, allergies and other health information;
(m) bank statements; and
(n) photographs and/or images of you from camera footage.

We collect and record Personal Information about individuals such as:
(a) children and their parents, carers, relatives and the emergency contacts provided;
(b) our customers, potential customers and their representatives;
(c) our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;
(d) our contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us;
(e) our employees past and present, including applicants; and
(f) any other person who comes into contact with Clever Cookies.

How and when do we collect Personal Information?

We collect your Personal Information to allow us to conduct our business functions, to provide market and sell our products and services. In some circumstances the collection of Personal Information may be required by law.

We may collect your Personal Information in the course of providing you with goods or services, or:
(a) when your child is registered or put on a waiting list;
(b) when you use or buy our products or services;
(c) when you provide us, or you offer or apply to supply us, with goods or services;
(d) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
(e) when you request information about us, our products or our services;
(f) when you provide feedback to us;
(g) when you visit or fill in a form on our Website;
(h) when you visit premises from which we operate;
(i) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations;
(j) when you submit a job application to us;
(k) when you otherwise contact us by telephone, fax, email, social media, post or in person; or
(l) where we are otherwise required or authorised by law to do so.

Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

We may also collect Personal Information about you from third parties and other sources such as:
(a) your nominated representatives;
(b) publicly available sources of information; and
(c) related entities, companies and businesses of Clever Cookies,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this Personal Information directly from you or if we are otherwise permitted to do so.

The Personal Information we collect may include sensitive information, including health information and biometric information. We will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

In most cases If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

Information collected via our Website

Third party content (eg social media links)

Some of the content on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may

facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

Use of your personal information

We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers.

We may collect, hold and use your Personal Information:
(a) to care for your child;
(b) to identify and communicate with you;
(c) to enable us to provide you with requested information, products or services;
(d) to otherwise assist customers by providing them with information and support;
(e) to collect and process payments from you;
(f) to help us to manage and enhance products or services we provide to you;
(g) to help us to manage and enhance goods and services we procure from our suppliers and subcontractors;
(h) to personalise and customise your experiences on our Website;
(i) to manage and administer any account you may hold with us;
(j) to promote and market our products and services to you;
(k) to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners;
(l) to conduct research for the purposes of improving existing products or services or creating new products or services;
(m) to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally;
(n) to provide for the safety and security of workers and onsite visitors;
(o) to help us manage our business operations;
(p) for our business support purposes including maintenance, backup and audit;
(q) to process any job application submitted by you;
(r) to respond to any queries or complaints you may have; or
(s) to comply with our statutory and legal obligations.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
(a) in accordance with this Privacy Policy or any agreement you enter into with us; or
(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

When do we disclose your Personal Information?

Clever Cookies may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in the paragraph above. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal

Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

We may also disclose your Personal Information to:
(a) any of Clever Cookies’s internal divisions, business units or departments;
(b) your nominated representatives, carers and relatives;
(c) other organisations or individuals who assist us in providing products and services to you;
(d) professional service providers and advisors who perform functions on our behalf, such as lawyers;
(e) medical providers including medical and rehabilitation practitioners for assessing insurance claims; and
(f) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development).

We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

We may also disclose your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of Clever Cookies, our business or any of our assets, including in insolvency, in circumstances which require the purchaser or potential purchaser to use such Personal Information consistently with this Privacy Policy.

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.

We may use and/or disclose your Personal Information for direct marketing purposes, unless you opt out (which you can do so at any time in accordance with this Privacy Policy or by writing to Level 2/63 Church Ave, Mascot NSW 2020). We are not likely to disclose your Personal Information to overseas recipients.

Storage and security of Personal Information held by us

We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.

If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.

Accessing Your Personal Information

You have a right to access your Personal Information, subject to exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. Clever Cookies reserves the right to charge a fee for searching for, and providing access to, your Personal Information on a per request basis.

You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, Clever Cookies may charge for providing access to this Personal Information, however such charge is unlikely to be excessive. There may be some legal or administrative reasons to refuse access. If we refuse your request to access your Personal Information, we will provide you with reasons for our refusal where we are required by law to give those reasons.

We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete Personal Information about yourself as requested, and properly update the Personal Information provided to us to keep it true, accurate, current and complete.

Please contact us if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the Personal Information.

It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

Information and photos within the Parent Corner

How do we deal with complaints?

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us and advise us as soon as possible. We will investigate your queries and complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you in writing of the outcome of our investigation.

We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: www.clevercookies.com.au where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We encourage you to check this page from time to time for any changes.

Changes to this Privacy Policy