Privacy Policy

This Privacy Policy (Policy) sets out, in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) the way in which Co-Hab Tonsley Limited (ACN 602 663 829) and its associated entities may collect, store, use, disclose, manage and protect your Personal Information

1.1 Co Hab may access data By:

(a) attending and using Co-Hab and its bookable share facilities (including but not limited to meeting rooms, large function room, boardroom and kitchen facility) (Services);

(b) accessing, requesting information on, enquiring about, using, receiving or providing feedback in relation to, Co-Hab’s operations or Services (online, in writing, by telephone or in person);

(c) seeking employment with us; or

(d) otherwise providing, or consenting to the collection of, Personal Information by Co-Hab, its officers, agents or employees,

after this Policy has been brought to your attention, you acknowledge and consent to the use, collection, storage or disclosure of your Personal Information by us in accordance with this Policy and the Privacy Act.

1.2 If you do not agree to us handling your Personal Information in the manner set out in this Policy we will not be able to provide our Services to you and you should not provide us with any personal information.

1.3 Our Data Breach Policy forms part of this Policy and sets out our approach to any data breach.

  1. Personal Information.

2.1 We follow the definition of Personal Information given in the Privacy Act:

“Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a)whether the information or opinion is true or not; and

(b)whether the information or opinion is recorded in a material form or not.”

  1. What kinds of Personal Information might we collect and hold?

3.1 The Personal Information we may collect, hold and process about you depends upon how you interact with us and what services, products or memberships you use, acquire or are involved in. This information may vary depending on the specific needs of Co-Hab, however, it may include your:

(a) name, address, email address, telephone and mobile number, fax number, business locations, areas of specialisation or interest, associations or organisations that you are a member of and identification information;

(b) your image, likeness or the sound of your voice;

(c) requests, enquiries and information you input into our website to access our Services;

(d) information about how you interact with us, our staff or our customers online, including via social media;

(e) demographic information such as age or date of birth, location and activities;

(f) business relationship and history with us;

(g) business or associated companies or entities;

(h) messages, emails, voicemail and other correspondence and frequency of enquiries;

(i) comments and feedback and responses to surveys;

(j) interaction with websites, including our website;

(k) information about how you use our website;

(l) what computer configurations and software you use;

(m) your IP address and/or other device identifying data;

(n) general preferences and interests;

(o) billing and credit card information;

(p) footage collected from closed-circuit television (CCTV);

(q) other information required to provide a service or information you have requested from us;

(r) information collected by Cookies, Web Beacons and other technologies; and

(s) any additional information relating to you that you provide to us.

3.2 We will not generally collect Sensitive Information concerning you unless you have consented or it is require by law. In some circumstances however, we may be required to collect and hold Sensitive Information. We will generally only collect Sensitive Information if you have a medical incident at Co-Hab Tonsley. In all cases, we will treat your Sensitive Information appropriately and with respect.

  1. How do we collect Personal Information?

4.1 We collect Personal Information:

(a) directly from you (when you provide that information to us, when we contact you, when you contact us, when you use our services or attend Co-Hab Tonsley; when you engage with us or when we engage with you);

(b) when conducting and/or providing our Services;

(c) by CCTV at Co-Hab Tonsley for 24 hour video surveillance, which monitors and records activity in the following areas:

•Above main entry door way,

•covering the open area (co-working desk)

•in the kitchen

(d) when you complete our standard forms;

(e) when you participate in our marketing activities;

(f) from third parties who you have authorised to provide us with information;

(g) through membership registrations and program applications;

(h) from publicly available sources such as the internet and social media; and

(i) when required to do so by law.

  1. How do we hold and secure your Personal Information?

5.1 We store your Personal Information digitally and in hard copy (unless legally required to retain in hard copy format). All hard copy material is secured onsite at the registered office of Co-Hab

5.2 All digital material (including CCTV footage) is secured using password protected computers and databases and only accessible by persons authorised by Co-Hab. Any digital transfer of Personal Information is via secure channels such as HTTPS where possible, and user passwords are encrypted using a one-way hash.

5.3 Any database we manage is only accessible through a local network connection. All confidential documents are securely shredded by a third party provider after storage is no longer necessary.

5.4 Co-Hab primarily uses data storage providers located inside Australia. However some data may potentially be stored overseas, most likely the United States, due to the use of third party services from businesses that originate in the United States. Where appropriate, Co-Hab has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods.

5.5 We conduct regular audits of our compliance with this Policy and the Act to ensure that our privacy framework is in line with industry best-practice.

5.6 The Data Breach Policy is a component of, and supports, our Privacy Policy. Refer to our Data Breach Policy on how we will manage any loss or unauthorised access or disclosure of your personal information should it ever occur.

5.7 The footage will be retained for 12 months and then it is destroyed.

  1. Why do we collect, hold, use and disclose Personal Information?

6.1 Co-Hab may collect Personal Information for a number of reasons, including:

(a) providing you or a third party with our Services;

(b) providing you with information about our Services;

(c) sending communications you request or contacting you and responding to your enquiries;

(d) providing third parties with information about you and your activities;

(e) cooperating with law enforcement bodies and government agencies where required by law or the terms of any relevant licence or industry code of practice;

(f) communicating with you and providing you with information about your account with us and our Services;

(g) ensuring consistency of service across our business and other internal business purposes;

(h) tailoring, developing or refining our Services including providing you with marketing material or contacting you in relation to our activities or Services;

(i) notifying you about changes to our website or Services we offer or provide via our website;

(j) publishing testimonials you provide us; and

(k) internal business purposes, corporate governance, auditing and record keeping.

6.2 Our use of Personal Information may extend beyond the uses described above in clause 6.1, but will be restricted to purposes that we consider to be related to our functions and activities.

6.3 We use Personal Information collected by CCTV is for a number of reasons including (but not limited to):

(a) to deter any form of aggressive, harmful, or unlawful behaviour at Co-Hab;

(b) ensuring occupational health and safety of occupants, visitors, contractors and other persons attending Co-Hab and responding to any occupational health and safety complaints;

(c) preventing and reducing theft or damage to property at Co-Hab;

(d) responding to incidents within or nearby Co-Hab and assisting with law enforcement agencies where an incident occurs at Co-Hab.

  1. What do we do with your Personal Information?

7.1 If we collect Personal Information other than by CCTV, we may:

(a) use that information for the purposes stated in this Policy and directly related purposes;

(b) store that information in accordance with this Policy;

(c) pass that information amongst entities we work with including:

(i) event organisers, participants, speakers, facilitators, sponsors, and potential sponsors to enable assessment of whether to sponsor an event or

participate in our activities;

(ii) mailing houses, printers and courier services;

(iii) education providers; mentors and consultants;

(iv) advertising organisations and sound and image recording organisations;

(v) international organisations with which we have agreements or arrangements;

(vi) market organisations and market research companies;

(d) pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, and other service providers); and

(e) provide that information to third parties as required or allowed by law.

7.2 If we collect the Personal Information by CCTV, we will only disclose the CCTV footage to a third party for the following limited purposes:

(a) for one of the reasons identified in clause 6.3 of this Privacy Policy which includes circumstances where Co-Hab believes the disclosure is:

(a) necessary to ensure the health and safety of occupants, visitors, contractors and other persons attending Co-Hab;

(b) of a person who poses a risk to the other uses of Co-Hab and is intended to be a warning to other Co-Hab uses to avoid harmful or unlawful behaviour; or

(c) for appropriate action to be taken to prevent or respond to aggressive, harmful or unlawful behaviour engaged in at Co-Hab.

(b) if the identity of the individual in the CCTV footage would not be unreasonably compromised in accordance with Co-Hab’s obligations under the any applicable law;

(c) if all of the individuals identified in the CCTV footage consent to its disclosure in writing and the disclosure is permitted by law, or the disclosure is required by law.

7.3 If CCTV footage is disclosed by Co-Hab in accordance with this Privacy Policy, Co-Hab will take all steps necessary to prevent the identity of persons in the footage from being disclosed where the disclosure of the footage is not of that particular individual. Such steps will include pixelating the faces or other personal identifiers of those individuals from the CCTV footage.

  1. Do you use my information for Direct Marketing?

8.1 We may use your Personal Information to communicate directly with you to promote our Services.

8.2 We use direct marketing to provide you with information about our Services that we believe you may be interested in.

8.3 If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable.

  1. What about Cookies, pixels and analytics?

9.1 When you access our website or social media channels, or when you use our Services, we may receive information about you via automated methods, including (but not limited to) use of a ‘cookie’, a ‘pixel’ or from analytics software.

9.2 These are tools that our web server may direct your traffic to, send to your computer, or embed on a website, when you visit our website. These tools help us provide Services to you, and to recognise when you re-visit the website, serve you customised content and to optimize your experience.

9.3 You may be able to change the settings of your browser so that Cookies are not accepted generally or that you are provided with options to accept or reject them as they are sent to your browser.

  1. Do we ever send your information overseas?

10.1 Co-Hab is an Australian based organisation however our data may be stored in the cloud in Australia.

10.2 We may need to share Personal Information with our overseas service providers. This can be a result of uploading images and/or footage to our social media accounts from time to time. The social media accounts may be hosted on an overseas server. Where applicable, in the event that your information is sent overseas, we will use our best endeavours to ensure that any overseas supplier will keep all Personal Information secure.

  1. Can you access your Personal Information or request it be corrected?

11.1 You may request access to the Personal Information that we hold about you by contacting us in writing. Upon receiving an access request we may request further details from you to verify your identity.

11.2 We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction. An administrative fee may be charged to cover our costs in providing you with access to your Personal Information. This fee will be explained to you before it has been incurred.

11.3 We will respond to your access request within a reasonable period of time by:

(a) providing you with access to your Personal Information ;

(b) rejecting your access request, and providing you reasons for this rejection.

11.4 Access requests may be denied where:

(a) we believe your request is frivolous or vexatious;

(b) we are entitled to reject a request by law;

(c) we are unable to verify your identity; or

(d) you have not paid the administrative fee (if any).

If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us. We will review your Personal Information and respond to the request within a reasonable period of time.

  1. Sensitive Information

We will only keep your Sensitive Information whilst you consent to us doing so, or if we are required to by law or to protect a legal right. If you want us to delete your Sensitive Information you may request we do so in writing. This may, however, limit our ability to serve and assist you.

  1. What happens if you want to deal with us anonymously or using a pseudonym?

When contacting us, you can do so either anonymously or by using a pseudonym. If you do so, we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our operations and services. Further, we may not be able to investigate incidents or complaints you have made.

  1. Does this Policy ever change?

From time to time we may make changes to this Policy at our discretion. When we do, we will highlight those changes in yellow highlight for a period of 14 days. Please make sure you review the Privacy Policy each time you visit our website to keep up to date on any changes.

  1. What happens if you have a question or complaint about how we have handled your Personal Information?

If you have a question or complaint, you can raise it with us by contacting us at:

To: Privacy Officer Co-Hab Tonsley Limited ACN 602 663 829 Level 1, Mitsubishi Building, 1284 South Road CLOVELLY PARK SA 5042 Ph: +61 448 053 024 Email:[email protected]

We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity.

If you are not satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at