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Privacy Policy

Purpose

Pulse Climbing is committed to providing quality services to you. This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/ 

Scope

The Policy applies to all persons engaging with .

Commencement

Effective from 16 June 2023, the Policy supersedes all previous versions, regardless of their form, whether written or unwritten.

Policy Details

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, and phone numbers.

This Personal Information is obtained in many ways including by speaking with us, attending our gyms, completing our waiver, by correspondence, by telephone, by email, via our website www.pulseclimbing.com.au, from other publicly available sources, from cookies and from third parties. We don’t guarantee website links or policies of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing, or by clicking the unsubscribe button.

Examples of how we may use your Personal Information:

  • Name, address – for identification purposes.
  • Date of Birth – for identification purposes, to determine your eligibility to climb and belay, to determine the correct pricing.
  • Climbing and belaying proficiencies – we record these so we have a record of which climbing related activities we have trained you to safely undertake.
  • Course enrolment forms/questionnaires – to help us cater to your specific requirements/situation.
  • Log-ins – to maintain safety and for business planning.
  • Sales/bookings records – for business planning and ease re: refund/faults etc.  

 

How we store your personal information

Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act.

Pulse Climbing will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, and that the information it holds is accurate, complete and up to date including through appropriate physical and electronic security strategies.

Only authorised Pulse Climbing personnel are provided access to Personal Information, and these employees are required to treat this information as confidential. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will destroy or permanently de-identify these records.

Our policy is that electronic records are only stored within Australia whenever this is commercially feasible. However, on occasion, a limited number of specialist software applications may involve the storage of personal data at an overseas location where a suitable alternative is not available.

Sensitive Information

Sensitive Information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

  • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  •  With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

 

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

  • Third parties where you consent to the use or disclosure; and
  • Where required or authorised by law.

 

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Pulse Climbing will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

 

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

 

Complaints

We have a procedure to resolve privacy complaints and enquiries. We will ensure that all complaints and enquiries are dealt with in a reasonable timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision (in respect of a complaint).

If you wish to make an enquiry about your personal information, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please write to us at 10/122 Garden Grove Pde, Adamstown, NSW, 2289.

In order to resolve a complaint, we:

  • will liaise with you to identify and define the nature and cause of the complaint;
  • may request that you provide the details of the complaint in writing;
  • will keep you informed of the likely time within which we will respond to your complaint; and
  • will inform you of the legislative basis (if any) of our decision in resolving such complaints.

We will also maintain a record of your complaint in a Register of Complaints.

If a party has lodged a complaint with us and is not satisfied with our response, they may contact the Office of the Australian Information Commissioner.

Breaches

All employees are obligated to adhere to this Policy without exception. Instances of recurrent breaches of the Policy will result in disciplinary measures, including the potential termination of employment.

Variations

Pulse Climbing maintains the right to modify, substitute, or terminate this policy periodically as deemed necessary.

Contact Information

Should there be any inquiries or concerns regarding the Policy, employees are encouraged to reach out to either their respective Location Gym Manager or the Managing Director for assistance.

Policy Version and Revision Information

Policy Name Privacy Policy
Policy Version 1.1
Original Issue Date 12 April 2023
Authorised by Scott Forrester, Managing Director

Document Details Date
Prepared by  Feather Fellows June 2023
Reviewed by Louise Shearston June 2023

Revision due  June 2024