Privacy policy

Explore our privacy policy to understand how Paddl secures and protects your information.

This privacy policy relates to how Paddl Pty Ltd ACN 161 428 459 (Paddl) collects and handles your personal information.  In this policy “we”, “our” and “us” refers to Paddl.  The website, located at https://paddl.com and incorporating our web app (Website), and the associated application known as Paddl (Application), are owned and operated by Paddl Co Pty Ltd ACN 131 952 004  (Paddl).

For the purposes of this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.  The Privacy Act 1988 (Cth) (Act) defines certain types of personal information to be "sensitive information".  Sensitive information includes health or genetic information and information about an individual's racial or ethnic origins, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record and certain aspects of a person's biometric information.

This Privacy Policy explains how we will treat your personal information that you provide to us in any way.  We are committed to maintaining the confidentiality and security of your personal information and managing it in an open and transparent way.

1. Using a Pseudonym or Being Anonymous

Wherever it is lawful and practical, you have the option of using a pseudonym or not identifying yourself when dealing with us. However, by doing so, you acknowledge that it may affect our ability to provide our goods and services to you. You will need to provide us with accurate personal details when you sign up to Paddl.

2. Collection of Personal Information

Types of information collected
‍In the process of conducting our operations and providing our services, we collect a range of personal information about our current and prospective users, suppliers, agents, service providers, other business associates and the people who run the businesses we deal with.  This information can include such things as name, email and/or street address, postcode, date of birth, gender, school, educational and work history and qualifications, prior and current employers, place of work, work experience, information about an individual's personal history, relationships, social connections and ambitions.

‍Collection of information via our Website and Application
‍We use analytics tracking in our Application and Website, “Cookies” on our Website and questions voluntarily answered in our Application by users.  Cookies are small files that are transferred to your computer's hard drive through your web browser and enable our site to recognise your browser and remember certain information.  We use cookies and tracking software to compile aggregate data about site traffic, site interaction and usage of the Application and Website so that we can offer better experiences and tools in the future.  A cookie cannot retrieve any other data from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information.  You should note that accepting cookies is required if you want to view the Site, because they are essential for the Site administration and security.

‍Ways we collect your personal information
‍Where possible we collect your personal information directly from you or through your use of the Application and Website.  We may also collect your personal information through correspondence with you (whether by letter, facsimile, text, telephone, forms or email).

We may also collect personal information about you from third parties in limited circumstances.  For example, if you participate in a Paddl or other workplace program, seminar or workshop we may collect your personal information from your employer and, if you sign up for an Account through a third party platform, we will collect your personal information from that platform on sign-up.

3. Purposes for which we collect, use and disclose personal information

We may collect, use and disclose your personal information for the following purposes:

(a) providing our services and resources (including personalised dashboards in the Application and Website, workplace and in upskilling, learning and development training programs) to you; 

(b) improving and continuing to develop our services; 

(c) informing you of services which may be of interest to you; and 

(d) making personalised recommendations to you regarding use of the Application and Website;

(e) to provide information to allow you to link to Products and services and/or offer or promote our Products and services;

(f) to process and respond to requests;

(g) to manage and conduct our business;

(h) to obtain feedback;

(i) to help us manage, develop and enhance our services; and

(j) to comply with our legal obligations, resolve any disputes and enforce our agreements and rights with third parties. 

De-identified information 
‍We may use de-identified data, other data and data regarding use of our Website and Application for purposes including research and analysis, case studies, marketing and improving and continuing to develop our services. 

4. Disclosing your Personal Information

We may disclose personal information to:

(a) our related entities, agents and affiliates and service providers who assist us in providing our services (including hosting and data storage providers such as Amazon / Microsoft Web Services) or responding to your enquiries;

(b) organisations we contract to provide services on our behalf, such as for data storage;

(c) various regulatory bodies and law enforcement officials and agencies to protect against fraud and for security purposes; 

(d) anyone to whom part of all of our assets or businesses may be transferred or sold; and

(e) our professional advisers, including lawyers, accountants and auditors.  

Where we engage third party contractors to perform services for us, those third party contractors may be given access to your personal information for the purposes of providing services to us.  Under these circumstances, however, those third party contractors must safeguard this information and must only use it for the purposes for which it was supplied.  If we give a third party service provider your personal information, we will also make them aware of this Policy and ask that they handle your personal information in accordance with it.  However, beyond this, we will not be liable if they do not comply with this Policy.

5. Direct Marketing

With your consent (where required), we may use your personal information (including your sensitive information) to provide you with information regarding our services and identify and provide you with customised recommendations regarding use of our Application or Website (either by email, text message or through the Application or Website). 

Unless you have agreed otherwise and except as otherwise specified, we will not use or share, either within Paddl or with a third party (including affiliates), any information collected from you for direct marketing purposes.

We will always provide a simple means for you to “opt-out” from receiving direct marketing, which typically involves an “opt-out” or “unsubscribe” link on emails, a check box on the collection notice or through a pop-up on your screen when you provide personal information on our Website or via the Application.

If at any time in the future you do not want us (or one of our service providers) to send you direct marketing material or you wish to cancel a previous consent, please inform us by contacting us at support@paddl.com. We will affect the change in a reasonable time and without charge.

6. Cross-border Disclosure of Personal Information

We will generally endeavour to store your information on an Australian server. However, in circumstances where this is not practical, we may disclose your personal information to an overseas entity.  We may also disclose your personal information to our service providers who are based overseas. 

7. Ratings and Feedback

Users of the Website and Application may have the option to review and rate Products. You consent to your ratings being publicly available on the Website.  By submitting your personal information to us (including your details as a user or employer), you will be treated as having given your permission for the processing of your personal data as set out in this Policy.  Paddl can republish your content as outlined in the Terms and Conditions.

We may ask for your feedback through surveys, and we may use the results for marketing or development of the Site.  We may also share the results with our affiliates, consultants, vendors and service providers.  As part of registration as a user on the Website or Application, you have agreed to receiving requests for feedback from Paddl via your email address.

8. Links to Third Party Websites

You can link to other third party websites from the Website. We are not responsible for the privacy policies and practices of other websites, even if you access them using links from the Website. We make no promises or guarantees regarding data collection on the hyper-linked pages and on websites that are not owned by Paddl. We recommend that you check the policy of each website you use, visit, or link to, and contact the owners or operators of such websites if you have any concerns or questions.

9. Security and Storage of Personal Information

We store your personal information electronically. Electronic information is stored by a third party storage provider.  We will take such steps as are reasonable in the circumstances to protect your personal information:

(a) from misuse, interference and loss; and

(b) from unauthorised access, modification or disclosure.

When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.

10. Access to and Correction of Personal Information

We will take such steps as are reasonable in the circumstances to ensure that your personal information we collect, use or disclose is accurate, up-to-date, complete and relevant.

You may request access to or correction of the personal information we hold about you at any time by making a request in writing to support@paddl.com.  Subject to any applicable exemptions, we will provide you with access to your personal information or correct your personal information (as applicable) within a reasonable amount of time.  If we decide to refuse your request, we will provide you with a written notice that sets out:

(a) the reasons for the refusal; and

(b) the mechanisms available to complain about the refusal.

11. Making a Complaint

If you have a concern or complaint relating to our handling of your personal information or any breaches of the APPs, please notify us at support@paddl.com with details of the nature of the complaint.  We will endeavour to respond to your complaint within 30 days of receipt. 

If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:

GPO Box 5218, Sydney NSW 2001
Email: enquiries@oaic.gov.au
Tel: 1300 363 992

12. Your Acceptance

Our Policy should be read in conjunction with the Terms and Conditions which are available on the Website.

By viewing and using the Website and/or the Application, you agree to the matters described in this Policy.  Further, you should review this Policy regularly, as it may be updated from time to time, at Paddl’s discretion.

This policy was last updated in January, 2022.