Our Privacy Policy

At The Formative Impact Co. we are committed to ensuring the privacy of our community is well protected. Whilst The Formative is not bound by the Australian Privacy Principles, we have developed a privacy policy which aims to achieve these standards to ensure your information is protected. When you access and use our site, this indicates you accept this policy and, in doing so, consent to the collection, use and distribution of information as described below.

Overtime the terms of the policy may change (when they do, we will change the date of the policy) and your use of the website tells us that you accept these changes. We recommend that you regularly review our privacy policy.

The content below is organised as follows:

  • What is personal information;

  • Types of information we collect;

  • How we collect information;

  • How we use that information;

  • How we protect the information collected;

  • General Data Protection Regulation;

  • Access to your personal information; and

  • How to contact us.


What is personal information?

Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

Sensitive information is a form of personal information and it includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. We will not generally collect sensitive information from you.

Types of Information We Collect

The types of information we collect include:

  • Contact and delivery details;

  • IP address;

  • Location;

  • Device (iPhone, laptop, etc);

  • Web browser (Safari, Firefox, etc);

  • Date and time of access and/or purchase;

  • Referral information – for example, the site you came from;

  • Account information (email address, credit card issuer, billing address details);

  • Information provided by you through a Small Giants Academy readers survey which might include your race, ethnicity, religion, political opinions and sexual preferences;

  • Information you post on our blog page when you submit a comment; and

  • Information you give us when attending our online events such as your name, story, image and voice.

The Formative Impact Co. and its related entities are not responsible for any information you’ve provided in public areas of our site, which may then be collected by other users.

We do sometimes collect sensitive information about you. This information is only collected where you have voluntarily provided it to us, for example, through a response to a reader survey or through your posts or comments on our website. The purpose of collecting this information is to assist us in providing you with products and services you love. By voluntarily providing your sensitive information to us you have consented to our collection and use of your sensitive information in accordance with this policy.

How We Collect Information

The Formative Impact Co. collects personal information in a number of ways, including when you:

  • Ask to be placed on a mailing list;

  • Subscribe to our services and become a customer;

  • Make an enquiry about our services;

  • Visit our website;

  • Supply goods or services to us;

  • Answer a Small Giants Academy readers survey;

  • Post a comment on our site;

  • Attend our recorded online events; and

  • Provide information to us.

Online Privacy

When you visit our website, ‘cookies’ allow us to identify movements around our site. What is a cookie you ask? Not the baked kind. A cookie is a small amount of information sent to and stored in your web browser by a website.

Cookies used in our website include an anonymous unique identifier that allows our website to recognise you and give you access to your account when you’re signed in. You need to accept cookies from this website in order to make purchases. The only personal information a cookie can contain is information you supply yourself.

How We Use Your Information

Primary Purpose

The information we collect will be used to help us:

  • Provide products and services to you;

  • Collect payment and deal with your account;

  • To communicate with you;

  • Improve the quality of our service;

  • For fraud-prevention purposes;

  • To purchase from you;

  • Promote and market our services to you including uploading recordings of our online events or using material from our online events, advising you of updates or changes to our products and services.

Because most of the information is collected directly from you, you will normally be aware of the purpose of the collection. We take all reasonable steps to ensure the information held is accurate, up-to-date, complete, relevant and not misleading.

Secondary Purpose 

Sometimes we might use the personal information we collect for a secondary purpose that is, for use in a way that is different from the primary purpose. We will only do this where:

  • You have consented (in some cases your consent will be implied);

  • The secondary purpose is related to the primary purpose and you would reasonably expect us to use the information is such a way; or

  • We are required or permitted by law to use the information in such away, or it is in the interests of public safety to do so.

But, one thing’s for sure; we will not sell any information we collect about you.

And finally, we will not transfer personal information overseas unless:

  • You have provided your consent; or

  • We check the overseas organisation has met certain requirements and can be enforced, so we continue to meet the requirements of this privacy policy; or

·       The transfer is necessary for the performance of the services between you and us in which case your consent is deemed to be given.

Marketing

When you provide your email address you agree to receive direct marketing material from our related entities and us. This allows us to tell you about our exciting new products and invite you along to events we think you’ll love.

If you wish to opt out of receiving any direct marketing you may unsubscribe from these emails by clicking on the link within the email or by advising us by sending an email to info@theformative.com.au.

Disclosure to Third Parties

As part of providing our products and services to you we may be required to disclose your personal information to third party organisations such as:

  • Our legal, accounting, financial or other professional advisers;

  • Outsourced service providers such as agencies that distribute and deliver our products to you and assist us with promotions or competitions;

  • Regulatory and other government agencies as required by Australia law;

  • A court, if required by a court order or other legally enforceable request such as an injunction or subpoena,

  • Our related entities;

  • A third party, if we merge with another entity or sell some or all of our business to a third party then your personal information and other data will be transferred to the new owner.

By continuing to use our services and website you consent to such disclosures to third parties.

How We Protect the Information Collected

We take all reasonable steps to protect your personal information from misuse, interference and loss and unauthorised modification, access or disclosure. The electronic database that holds the information is designed to restrict access to unauthorised persons.

The Internet is not secure and personal information you send to us via the Internet is done so at your own risk, so always be conscious of this.

Where we no longer require your personal information for a permitted purpose and it is not required to be retained by law, we will take reasonable steps to destroy or permanently de-identify it.

Data Breaches

We have internal processes in place to deal with any data breaches. Where there has been unauthorised access or disclosure of personal information and this access is likely to result in serious harm, we will, as soon as practicable possible, investigate the matter in an attempt to mitigate any harm caused.  

We will take reasonable steps to notify you if your information has been affected in this way.

General Data Protection Regulation

The General Data Protection Regulation (GDPR) refers to a set of data protection requirements which aim to create clear and uniform data protection laws that apply to European Union residents. If the GDPR applies to us, we will comply with the data handling regime in respect of any personal data of data subjects (residents) in the European Union that we may obtain.

The meaning of personal data is similar to personal information, however, it is broader as it includes any information relating to an identified or identifiable natural person.

The types of information we may collect from European Union residents include:

  • name;

  • email address;

  • phone number; and

  • billing and shipping address.

We will take appropriate steps to ensure that personal data is:

  • processed lawfully, fairly and in a transparent manner;

  • collected for legitimate purposes;

  • accurate and up to date;

  • kept for no longer than is necessary for the purposes for which it was collected; and

  • secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.

European residents have the right to access personal data we hold about them and to request that personal data be corrected, updated, deleted or transferred to another organisation. European residents are also able to request that the processing of their personal data be restricted or object to their personal data being processed.

To make any of these requests, please contact us through the contact details set out below.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:

  • such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other customers/clients subject to appropriate confidentiality protections; and

  • even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular;

  • to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and

  • in exercising and defending our legal rights and meeting our legal and regulatory obligations.

Access to Your Personal Information

You may request a copy of the personal information we hold about you by submitting a written request to hello@theformative.com.au. You will be required to verify your identity and to specify what information you require.

When you get the information, let us know if you think any of it is wrong or out of date and you can ask us to change it for you. If for some reason we can’t amend it, you may request we associate the information with a statement that the information is incorrect, out of date, incomplete, irrelevant or misleading.

We may refuse to give access to your information where this is allowed or required by law. If we do refuse to grant access, we will give written reasons explaining why.

Contact Us

If you have any questions, feedback or complaints about our privacy policy or our use of your information, please contact us at hello@theformative.com.au.

We will acknowledge and deal with any complaints as soon as practicably possible.