July 2021

Aged Care Gurus Pty Ltd (ABN 61 156 657 733) (‘we’, ‘our’, and ‘us’) endeavour to adhere to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy (Policy) sets out how we collect, use and share your personal information and how to contact us with any queries or concerns.

By voluntarily supplying us with your personal information you are agreeing to be bound by this Policy. While we may update our Policy from time to time, the most recent version of this Policy will always be available on our website.

This Policy also contemplates how we handle personal information we receive from third party users (“Third Party Users”) which includes members of the Aged Care Gurus Adviser Network, financial planners, accountants, and other personal advisers as well as our customers who use our software solutions as part of their retirement village business.

If we change the Policy in any material way we will post a notice on our website along with the updated Policy. We may also contact you via your contact information on file, for example by email, notification or some other equivalent measure.

If you have any queries, concerns or complaints about how we handle your personal information, please contact out Privacy Officer in the first instance:

Privacy Officer Contact: Jemma Briscoe

Postal Address:
Attention: Privacy Officer
Aged Care Gurus Pty Ltd

Our website contains links to other websites. When a user clicks on a link to another site they are no longer subject to this Policy.

1. What types of information do we collect and why?

In the course of providing our products and services to you, we collect personal and other information about you, how you interact with us, our products and our services. We also process the personal information of the clients, or potential clients, of Third Party Users who use our products and services. We collect personal information through a number of mechanisms, including:

1.1 Collection from you or your representatives: we collect and store information you provide directly to us (either in person, by a Third Party User, by email, by phone, or by any other direct means) in order to deliver our products and services. This includes:

• Contact information: such as your name, address, email address, telephone number;
• Personal information: such as date of birth and marital status;
• Financial information: such as your payment information (credit card, bank account, etc), information about your financial position, income streams, value of assets, pensions and other government entitlements; and
• Business and employment details: such as your employer or Australian Business Number.

1.2 Automatic: we use cookies (small text files stored on your devices that provide us with information such as your internet protocol (IP) address, server information, internet service provider, and information on how you interact with our website) and other services that allow us to understand how you use our online media. Cookies are used to facilitate the input of information into our website and online services.

We use Google cookies which track and measure user interaction and provides data to help improve our products and services.

If you opt-out of third party tracking technologies or elect to prevent the use of cookies, this may result in the loss of website functionality, restrict your use of the website or delay or affect the way in which the website operates.

1.3 Communications: when you communicate with us, we collect information such as your contact details (email address or phone number). We also engage third party services that provide us with information about how you interact with some communications we distribute. You can elect to not receive communications from us by contacting our Privacy Officer.

1.4 Third Party Users: Third Party Users who use our services to assist their clients or potential clients. In the course of using our services, they will submit, and we may have access to, their client’s personal information to us.

1.5 Analytics: our services include the use of your personal information to provide you with information about your estimated costs associated with different retirement options (for example retirement villages, land lease communities and/or residential aged care facilities) and any pension entitlements and rental assistance. During this process, we may generate new personal information from existing personal information about you.

1.6 Sensitive Information

We collect information considered to be sensitive information or information that clearly implies sensitive information in the Privacy Act. We collect spouse and health information in order to provide our services to you.

We will either collect this information directly from you or from a Third Party User using our services, provided there are express consents in place in respect of the collection and disclosure of sensitive information.

You have the option of not identifying yourself or interacting with us using a pseudonym. However, this may not be practicable when engaging our services.

2. How do we use your information?

We will only use your information for the purposes for which it was collected (primary purpose) or a purpose related to that primary purpose if it would be reasonably expected by you or where we have separately obtained your consent.

We use personal information for the primary purpose of providing you or your Third Party User with a series of retirement living options and the associated costs, including any pension entitlements.

How we use the personal information we collect and receive depends, in part, on which services you use, how you use them and any preferences you have communicated to us. If you would like to restrict how your personal information is handled beyond what is outlined in this Policy, please contact our Privacy Officer.

2.1 Disclosure of personal information to third parties

We may disclose your information to third parties who assist us in providing, managing and administering our products and services. We will also disclose your personal information where such disclosure is required by law.

Where your personal information has been submitted to us by a Third Party User, we will disclose the outcome of any data processing to that Third Party User.

We disclose your personal information to third parties that:

• Manage and enhance our customer database;
• Assess your interest in our products or services;
• Conduct customer research or satisfaction surveys including; and
• Send marketing information to you on our behalf.

We do not sell or license your information to third parties.

3. How do we store and secure the information we collect?

We store your personal information as physical files and in encrypted databases. Security and management of personal information

We will take reasonable steps to protect the personal information we hold from misuse, loss, and unauthorised access, modification or disclosure. We do this by:

• Putting in place physical, electronic and procedural safeguards in line with industry standards;
• Requiring any third party providers to have acceptable security measures to keep personal information secure;
• Limiting access to the information we collect about you;
• Imposing confidentiality requirements on our employees;=
• Only providing access to personal information once proper identification has been given;
• Ensuring all websites and online systems utilise Secure Sockets Layer (SSL) Certificates; and
• Utilising secured data hosting with encrypted databases for applicable online services.

While we take all steps reasonable in the circumstances to protect your information, in the unlikely event a data breach occurs, we will notify you in accordance with our obligations under the Privacy Act.

If we no longer require your personal information, and are not legally required to retain it, we will take reasonable steps to destroy or de-identify the personal information.

3.1 Sending information overseas

Personal information is sent overseas in limited circumstances. We send personal information to Infusionsoft, a company based in the United States, which has access to personal information including names, addresses, purchase history, phone numbers and emails of our customers in order to provide us with customer data management services.

We take all steps reasonable in the circumstances to ensure that those we disclose personal information to overseas protect your information. This includes the use of contractual arrangements to control how third parties use and handle personal information overseas.

We utilise data centres located in countries overseas such as the United States of America. While we may store information overseas, this information is not provided or disclosed to other entities overseas except as otherwise provided for in this Policy.

4. How to access and control your information?

4.1 Accessing the information we hold about you

The Privacy Act allows you to request a copy of the personal information that we hold about you. To make a request to access this information please contact us in writing. We will require you to verify your identify and specify what information you wish to access. If eligible, we will grant you access to the information within 30 days.

We may charge a fee to cover the costs of verifying your application, and retrieving, reviewing and copying any material requested.

4.2 Updating your personal information

All personal information held by us has either been provided by you or a Third Party User. If you believe that the information we hold may be inaccurate or incomplete, please follow the below processes:

4.3 Personal information provided directly to us by you

Please contact us at the details above if you believe that the information we hold about you requires correction or is out of date. We endeavour to process any request within 30 days and will provide written reasons if your request is rejected, as well as providing details for making a complaint about the refusal if necessary.

For corrections to credit information we will provide, where practicable, written notice of the correction to any entity we have disclosed this information to previously.

4.4 Third Party Users

If your personal information was provided to us by a Third Party User, we encourage you to contact the Third Party User in the first instance. If you are unable to contact the Third Party User, please contact us at the information above.

5. Complaints

If you are concerned that we have not complied with your legal rights or the applicable privacy laws, contact our Privacy Officer in the first instance. Please contact our Privacy Officer (contact details above) with a thorough description of your concerns and a response will be provided within a reasonable period. All complaints must be in writing.

When processing a compliant, we will require you to provide us with information to confirm your identity before processing a request related to information we may hold about you.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:

Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

For more information on privacy see the Australian Information Commissioner’s website.