Privacy ↘︎
Digital Balance Australia (Digital Balance, DBA) is committed to protecting your privacy and the confidentiality of your:
- Personal Information and Sensitive Information as defined in the Privacy Act 1988 (Cth) (Privacy Act); and
- your Personal Data as defined in the EU General Data Protection Regulation 2018 (GDPR),
together, your (Information).
This Privacy Policy explains, in further detail, the types of Information we collect, how we collect and use this Information, who we may disclose it to, how you can access and change your Information and how you can make a privacy complaint.
Our Privacy Policy ↘︎
What kinds of Information do we collect?
The types of Information that Digital Balance may collect and hold includes the following:
- full name, postal address, e-mail address, telephone and fax numbers;
- occupation;
- date of birth, gender and marital status;
- any other information you provide to us by any means;
- information associated with web browsing, such as your IP address and web cookies; and
- information relating to a child under 16 if parental consent has been given.
Digital Balance may collect the Information of anyone over the age of 16 years. If Digital Balance wishes to collect the information of anyone under 16 years of age (child), Digital Balance must seek the consent of such collection from a person that has parental responsibility over the child.
Generally, the kinds of information that Digital Balance will collect and/or hold will depend on the nature of our interaction with you – essentially, the purpose of the activity we are conducting. Accordingly, the kinds of information we record will usually extend to your name, address, contact details (including email addresses), payment information (such as credit card and bank account details) and cookie data.
On occasion we may collect and/or hold other kinds of Information – such as when we run a promotional event or a competition. When we do this, we will disclose our intention to do so to you.
At all times, Digital Balance will take reasonable steps to inform you of the kinds of Information it collects and holds when you are engaged with it, and how this may vary from project to project.
What kinds of Information can we hold?
We are permitted to collect and/or hold, with your consent, the following kinds of Information:
- Personal Information, being information or an opinion about an identified individual, or an individual who is reasonably identifiable, including, but not limited to information in relation to criminal convictions and offences.
- Personal Data, being any information which is related to an identified or identifiable natural person that resides within the European Union.
- Sensitive Information, being information or an opinion about an individual’s personal preferences or characteristics (such as race, ethnicity, political views, memberships, religious or philosophical beliefs and sexual preference), health information and/or biometric information.
- Special Categories of Personal Data, being personal data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union memberships, genetic data, biometric data, health status, or sexual orientation.
Sensitive Information (as defined in the Privacy Act) and Special Categories of Personal Data (as defined within the GDPR) are afforded a higher level of protection than other kinds of information under the Privacy Act and GDPR. We will only collect and hold Sensitive Information, and Special Categories of Personal Data, when you have given explicit consent for the processing of such data for one or more specified purposes. We will rarely collect and hold this kind of information.
How do we collect your Information and how do we hold it? ↘︎
How do we collect your Information?
Digital Balance may collect Information from or about you in a number of circumstances, including:
- from publicly available sources of information;
- when you use our services or contact us directly;
- when you sign up to receive information from us;
- when you take part in one of our competitions and/or promotions;
- when you use our website and/or via software, such as cookies and web/tracking pixels (also known as “web beacons”);
- when you provide or offer services to us;
- from third parties;
- from our own records at Digital Balance; and
- when legally required to do so.
Means of collection
Digital Balance only collects (and holds) Information when knowingly and voluntarily submitted by you. When you register your interest or otherwise in the course of us providing services to you, Digital Balance may need to collect Information which may include your name, address, telephone/mobile phone number, e-mail address, credit card details, your business name, your user ID or password.
Digital Balance only collects (and holds) Sensitive Information (as defined in the Privacy Act) and Special Categories of Personal Data (as defined within the GDPR) when knowingly and voluntarily submitted by you. Although Digital Balance will rarely hold and/or collect this kind of information, the information Digital Balance may hold includes your racial or ethnic background, your family status and/or financial information about you, such as your tax file number.
Digital Balance will, at all times, take reasonable steps to collect your Information directly from you, unless:
- it is unreasonable or impracticable for us to do so; or
- you consent to the collection of the Information from someone other than you; or
- we are required or authorised by or under the GDPR or Australian law, or a court/tribunal order, to collect the Information from someone other than you.
In the event we receive your Information from a third party, via referral and/or via a purchase list, we will take reasonable steps to inform you of that and seek your consent to our collection of that Information. Should you refuse to consent to that collection, we will take reasonable steps to destroy or de-identify that Information.
How we use your Information
We will only use your Information to the extent permitted by the law. We may use the Information you provide to us or which we collect for the following range of purposes, including:
- To register you as a new customer.
- To process and deliver your order/booking/purchase including:
- manage payments, fees and charges; and
- collect and recover money owed to us.
- To respond to any of your enquires, including those submitted online, by telephone or in person.
- To organise and provide you with a product or service you have requested, delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and to fulfil our obligations under any other agreement we may have with you).
- To provide you with checkout assistance when you use our website or services (including any online e-commerce stores). If you do not complete your purchase/booking, we may contact you using these details to offer our assistance (in case, for instance, you were experiencing technical difficulties that prevented you from completing a transaction).
- To manage our relationship with you which will include:
- notifying you about changes to our terms and conditions or Privacy Policy; and
- asking you to leave a review or take a survey.
- To enable you to partake in a prize draw, competition or complete a survey.
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- To use data analytics to improve and enhance our existing products, services and applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ preferences in general.
- To make suggestions and recommendations to you about goods or services that may be of interest to you, including carrying out surveys to better understand your preferences.
- To provide your Information to our advertising, marketing, social media and promotional agencies.
- To send information, marketing materials and newsletters to you.
- To prevent fraud and for investigation purposes, for example, using device information such as device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, checking that a payment is not made fraudulently.
- To create and manage customer database(s). As part of our ongoing customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accounts. Information may be linked via a unique identifier, such as a cookie or account number. Alternatively, we may decide to combine two or more databases into a single database of customer information. We may do this for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts.
- To consider employing you if you contact us via one of the job application areas or pages of our websites.
We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Social media
When you browse and make use of Digital Balance’s social media pages (such as Facebook, LinkedIn, X (Twitter), and YouTube), you are using an external site and are therefore subject to the privacy policies and practices of that site. If you have any questions or concerns regarding that site’s privacy policies and practices, you should review the privacy policy of the relevant site. Digital Balance does not endorse, and is not accountable for, any views expressed by third parties using that site.
Digital Balance records all information posted to its social media pages and uses that information for the purposes of administering the pages, for record keeping, for considering and/or addressing any comments made and for running competitions and campaigns. No attempt will be made to further identify social media subscribers except where requested and authorised by law.
Notification of collection
When Digital Balance collects Information about you, it will take reasonable steps to notify you or to otherwise ensure you are aware of certain matters. These matters include our identity as an organisation and contact details, the context of the collection, whether the collection is required or authorised by law, the purposes of the collection, Digital Balance’s usual disclosure of Information, information about our Privacy Policy, and whether Digital Balance is likely to disclose your Information to overseas recipients.
Digital Balance will take reasonable steps to provide this notification before, or at the time it collects your Information. If it is not possible for it to do so, Digital Balance will take reasonable steps to provide notification as soon as practicable after collection.
If you choose not to provide certain Information to us, we may not be able to provide you with access to parts of the Digital Balance website or to certain content, products and services available on the Digital Balance website or generally from Digital Balance.
How do we hold and store your Information?
All of the Information we collect is stored securely in digital formats with strict security measures. We do not hold hard copies of your Information and any Information collected via hard copy formats is transferred to digital storage and the hard copies are destroyed securely through confidential waste management.
Where Digital Balance collects your Information online, specifically, via digitalbalance.com.au when you perform the following tasks:
- Create a user profile on the website to utilise functionality
- Signing up to receive email communications from Digital Balance
Your email address and Information are stored within WordPress when you create a profile on digitalbalance.com.au and Brevo when you sign up to receive email communications from Digital Balance.
WordPress and Brevo are web-based marketing technology platforms that Digital Balance utilise in order to deliver its services.
Digital Balance will keep your Information only for as long as you want us to. You are able to opt-out or unsubscribe from our email communications at any time via the “unsubscribe” link in any of the marketing emails you receive from us.
If you’d like to delete your user profile on digitalbalance.com.au you can do so by logging in to your account and clicking the “delete my profile” link. If you have any problems with attempting to delete your information please contact us and we will happily remove it for you.
Security
Digital Balance strives to ensure the security, integrity and privacy of the Information of its clients.
Digital Balance takes reasonable steps to protect the security of all Information.
Digital Balance personnel are required to respect the confidentiality of Information and the privacy of individuals.
We use a variety of physical and electronic security measures, including restricting physical access to our offices and firewalls and secure databases to keep Information secure from misuse, loss or unauthorised use or disclosure.
This website is protected by a security tool called reCAPTCHA, a measure to prevent spambots from accessing the website and ensure the site is protected from malicious cyber attacks. Enabling this security measure on westernaustralia.com helps keep your Information safe and secure. For more information on how reCAPTCHA protects this website and your Information, visit Google’s Privacy Policy and Terms of Service.
Digital Balance continually reviews its various security measures in order to ensure that they are up to date and fit for purpose.
Information retention and destruction practices or obligations
Digital Balance will only retain your information as long as it is necessary for it do so (for example, this may be until the end of a given project or the end of a period of time for expressing interest in a development) or where and when it is required to do so by legislation or a court or tribunal order.
Digital Balance has an internal system that is used to identify information that is no longer necessary for it to retain and periodically reviews its data in accordance with this system.
Once the purpose for which the information was collected expires and/or upon periodic review, Digital Balance will take reasonable steps to destroy the information or to de-identify the information, so that it can be retained for statistical purposes.
Information which is retained for statistical purposes may be used to improve our services and to make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes
Unsolicited personal information
Digital Balance may receive your Information as unsolicited personal information.
Unsolicited personal information is received by an organisation, such as Digital Balance, where it took no active steps to collect that information.
When and where Digital Balance receives unsolicited information, Digital Balance will determine whether it could have collected the information under Australian Privacy Principle 3 (which governs the collection of solicited personal information) or Article 14 of the GDPR. Where Digital Balance could not have collected the information consistent with Australian Privacy Principle 3 and Article 14 of the GDPR, Digital Balance will destroy or de-identify the information as soon as practicable, so long as it is lawful and reasonable for it to do so.
The purpose of our collection, holding of, use or disclosure of Information
How and in what circumstances will Digital Balance use or disclose my Information?
Digital Balance may, in certain circumstances, collect, hold, use and/or disclose your Information.
Digital Balance will use and disclose your Information to provide our services to you or to fulfill administrative functions associated with these services. In general, we will use and disclose your Information for the following purposes:
- to communicate with you with respect to an existing event or booking;
- to provide and market our services or the goods/services of our partners or affiliates;
- to help us manage and enhance our services;
- to purchase from you;
- for any purpose for which the information was provided; or
- any other purpose related to any of the above.
Digital Balance will disclose Information when it permits that Information to become known outside Digital Balance and where it releases it from its effective control.
For example, Digital Balance would be said to have disclosed your Information where:
- it shares your Information with another entity;
- it publishes your Information on the internet so it is accessible by others;
- where one of its staff reveals your Information in the course of a conversation with a person who does not work for Digital Balance; or
- where one of its staff members sends a document containing your Information to someone who is not you.
Primary purpose and secondary purposes
Your Information will only be used and disclosed for the primary purpose for which it was submitted or for such other secondary purposes that are related to that purpose, unless we disclose other uses in this Privacy Policy or at the time of the collection of that Information.
We will only make use of or disclose your Information for a secondary purpose if:
- you have consented to the use or disclosure of that Information; or
- you would reasonably expect Digital Balance to use or disclose the Information for the secondary purpose; or
- the use or disclosure of that Information is required or authorised by or under legislation or court/tribunal order; or
- a “permitted general situation” exists in relation to the use or disclosure of the Information by Digital Balance; or
- Digital Balance reasonably believes that the use of the Information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
In the event Digital Balance discloses information, Digital Balance will make a written record of the use or disclosure.
When collecting your Information we will inform you of the primary purpose of our collection and/or any anticipated secondary purpose that may arise. The purpose of our collection will vary from project to project, depending on the nature of the project and the nature of your involvement and/or interest in the project.
Who can access my Information and what conditions apply to their use of my Information?
As a general rule, your Information will only be accessed and/or viewed by Digital Balance staff and officers, as and when it is appropriate or necessary. However, your Information may also be accessed, from time to time, by:
- Digital Balance contractors;
- Digital Balance project and/or marketing partners; or
- Digital Balance suppliers.
Where a party, other than an employee or officer of Digital Balance, has access to the Information of individuals, they will be required to comply with any applicable Australian privacy legislation and the GDPR.
The access and use of your Information by a third party will be restricted to the purpose for which it was first collected and/or to a closely related secondary purpose.
Use of Aggregate Data
Digital Balance may use Information in aggregate form to improve services and make them more responsive to the needs of customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
Direct marketing
Digital Balance will not use or disclose your Information for the purpose of direct marketing, unless:
- we collected the Information from you;
- we obtained your consent to the use or disclosure of the Information for that purpose (except where it was impracticable to do so), including by your use of the our website and the CMP, through which you chose to opt-in to the collection and use of cookies;
- you would reasonably expect Digital Balance to use or disclose the Information for that purpose;
- we provide you with an easy to use means of opting out of receiving any further direct marketing communications; and
- you have not requested that we cease sending you direct marketing communications.
Digital Balance will only make use of your Sensitive Information (as defined in the Privacy Act) and Special Categories of Personal Data (as defined within the GDPR) for direct marketing purposes if you have consented to the use or disclosure of that information for that purpose.
If you receive direct marketing communications from Digital Balance or from an associated entity, partner or affiliate, you are entitled to:
- request that you receive no further direct marketing communications from Digital Balance
- and/or the associated entity, partner or affiliate; and
- request that Digital Balance disclose the source of the information.
Opting-out
Digital Balance will facilitate any request by you to opt-out of receiving direct marketing communications.
This may be a request to opt-out of receiving certain communications or to opt-out altogether.
Digital Balance will not charge you for making such a request or for giving effect to such a request.
Digital Balance will take reasonable steps to give effect to such a request within a reasonable period of time after the request is made and will reply to a request for the source of the information in a reasonable period of time (unless it is unreasonable or impracticable for us to do so).
When visiting Digital Balance’s website, you may reject all (or some) cookies (except for strictly necessary cookies) by using the CMP. The CMP also allows you to request that your cookie data be destroyed or removed from processing and Digital Balance will take steps to facilitate such a request, to the extent that it is possible.
As mentioned above, Digital Balance makes use of a number of Google Analytics and Google Advertising Features, including remarketing.
If you would like to control or opt out of the application of the Google Analytics or Google Advertising Features, you should refer to Google’s guide(s) on opting out of those feature at: http://www.google.com/intl/en/policies/privacy/.
E-mails
We may use your e-mail address to send you Digital Balance publications, newsletters, marketing emails and information relating to seminars or events. We may also contact you by e-mail to seek your opinion or comment on our website and our service offerings.
Digital Balance, at all times, aims to comply with the terms of the Spam Act 2003 (Cth) and will not send unsolicited commercial electronic messages or “spam”.
All commercial electronic messages sent by Digital Balance include information about the individual or organisation who authorised the sending of the message.
You can unsubscribe from our e-mails at any time. You can also contact us and instruct us not to send further information to you.
How can you access your Information and/or seek the correction of your Information? ↘︎
Access to your Information
You have a right to access the Information we hold about you and to request the correction of any Information we hold about you.
Digital Balance will take reasonable steps to ensure that the Information it collects and discloses is accurate, up to date, complete and relevant.
You can make a request for access to your Information informally in writing (including under Article 15 of the GDPR). Digital Balance aims to, whenever possible, facilitate informal requests for Information.
Applications for access to your Information may be lodged in the following ways:
Enquiries:
FOI Coordinator
Telephone: +61 3 9002 4069
Email: hello@digitalbalance.com.au
In person (by appointment):
FOI Coordinator
Level 1, 112 Buckhurst Street
South Melbourne Vic 3205
By Mail
FOI Coordinator
Digital Balance Australia
Level 1, 112 Buckhurst Street
South Melbourne Vic 3205
Should you experience difficulty in determining the correct route through which to request access to your Information, please contact our Privacy Officer through the Contact Us form and they will provide you with assistance.
Digital Balance will take reasonable steps to respond to a request for access within a reasonable period of time after the request is made (within one month) and to give access to your Information in the manner requested by the individual, if it is reasonable and practicable to do so.
Digital Balance reserves the right to charge you a minimal fee for providing you with your Information if it forms the view that your request is unfounded or excessive.
In the event that Digital Balance refuses to give you access to your Information requested by you, we will give you a written notice which sets out the reasons for the refusal (except to the extent that it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
Retaining and deleting your Information
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of your Information.
Information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
In some cases it is not possible for us to specify in advance the periods for which your Information will be retained. In such cases, we will determine the period of retention by taking into consideration the period necessary for retention for its lawful purpose.
Notwithstanding the other provisions of this section we may retain your Information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Access to your Information and your rights
In this section, we have provided a summary of the rights that you have under current data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to be informed;
- the right to access;
- the right to rectification;
- the right to erasure, i.e. to be forgotten;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to confirmation as to whether or not we process your Information and, where we do, access to the Information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Information concerned and the recipients of the Information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Information. The first electronic copy will be provided free of charge, but additional copies in specific formats may be subject to a reasonable fee.
You have the right to rectify any inaccurate Information we hold about you and, taking into account the purposes of the processing, to have any incomplete Information about you completed.
You can make a request for the correction and/or amendment of your Information.
Applications to have Information held by Digital Balance corrected or amended should:
- be made in writing to the Privacy Officer;
- provide enough information to determine what changes are required; and
- provide your current contact details.
In the event Digital Balance refuses to correct your Information, Digital Balance will give you a written notice which sets out the reasons for the refusal (except to the extent it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
Digital Balance will take reasonable steps to respond to a request for correction or amendment without undue delay and will not charge you for the making of the request or for the correction of your Information.
In some circumstances you have the right to the erasure of your Information without undue delay. Those circumstances include:
- the Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- you withdraw consent to consent-based processing;
- you object to the processing under certain rules of applicable data protection law;
- the processing is for direct marketing purposes; and
- the Information has been unlawfully processed.
However, there are exclusions to the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your Information.
Those circumstances are:
- you contest the accuracy of the Information;
- processing is unlawful but you oppose erasure;
- we no longer need the Information for the purposes of our processing, but you require Information for the establishment, exercise or defence of legal claims; and
- you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Information. However, we will only otherwise process it:
- with your consent;
- for the establishment, exercise or defence of legal claims;
- for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your Information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the Information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your Information for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your Information is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and such processing is carried out by automated means,
- you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
To the extent that the legal basis for our processing of your Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Notifiable data breaches
Where we become aware of a potential data breach which is likely to result in serious harm to any individuals about whom we hold information, we will:
- investigate the suspected breach and determine scope of any breach that has occurred and the risk of harm to affected individuals whose information may have been compromised;
- notify you of the potential breach; and
- take steps to minimise any harm caused to affected individuals as a result of the breach.
How can I complain about a breach or give feedback on how Digital Balance deals with my Information?
Should you wish to provide Digital Balance with feedback with respect to its management of your Information, to complain about a breach of Digital Balance’s privacy obligations or to appeal a decision with respect to a request for access to or the correction of Information. Please contact us at the address set out at 99 below.
Digital Balance will take reasonable steps to respond to your complaint and/or feedback within 45 days.
In the event that you wish to have a decision refusing access to your Information and/or refusing to correct your personal data reviewed or to lodge a complaint with respect to the management of your personal data, please contact us.
Disclosure of Information to overseas recipients
Generally, Digital Balance does not disclose the Information of its customers to overseas recipients.
However, there is a possibility that, on occasion, your Information may be disclosed to an overseas recipient. The location of any recipients will vary depending on the project or purpose concerned.
In the event that a particular project or development will or may involve the disclosure of Information to an overseas recipient, Digital Balance will take reasonable steps to inform you of that potential use or disclosure as soon as possible. As part of our notification process, Digital Balance will inform you of the location and/or identity of that recipient.
Similarly with other third-party recipients and/or partners of Digital Balance, we will take reasonable steps to ensure that any overseas recipients comply with the Privacy Legislation.
Should you have any queries about the potential disclosure of your Information to an overseas recipient, please contact us.
If you have any queries relating to this Privacy Policy, or you have any feedback, please contact us.