Leap Sustainability Pty Ltd ABN 68 661 718 690 (“Leap Sustainability”, “we”) respects your privacy and is committed to protecting it. We take all reasonable steps to implement and maintain practices, procedures and systems to uphold your privacy rights in line with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

This document sets out how we collect and use your personal information during and after your relationship with Leap Sustainability. It applies to those that we engage with in the course of project delivery (such as our clients and their stakeholders), as well as to those that we engage with when performing other business and marketing functions (such as when you visit our website). In this policy we use to the term ‘you’, to denote those whose information we collect.

How do we collect information about you?

We collect information in a number of ways, including:

Directly from you

• when you provide information (such as an email address and personal details) by sending us a message, email, online request, phone or in documents;
• when you visit our website, social media pages or mobile applications or click on our advertisements on online media, which may provide us with information about your computer hardware or software (for example “cookies”);

Indirectly

• from third party sources and referees, personal contacts and industry connections such as our clients, suppliers or other market contacts;
• from an organisation you are involved with (for example, if you are copied into an email by a colleague);
• and via information collected and collated from publicly available sources, including search engines, websites, social media such as LinkedIn, publicly available data bases.

Cookies

Our website uses cookies to provide a better service to you. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Although cookies do not access information stored on your computer or any personal information, they do allow collection of identifiable information. Cookies allow our website to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Third party links

Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites or applications and are not responsible for their protection of your data. When you leave our website, we encourage you to read the privacy or transparency notice of every website you visit.

What sort of information do we collect?

The sort of information we collect, store and hold may include:

• your personal details such as your name, job title, email and/or physical addresses, telephone numbers, job title and location and industry you are involved in and other information to maintain our relationship with you;
• how and when you access our site;
• and what, how and when you have engaged us.

We will not collect personal information unless reasonably necessary.

Sensitive Information

Leap Sustainability will generally seek your express (verbal or written) consent before handling your sensitive information. We will, as far as practicable, implement procedures and systems to obtain and record consent. If we need to collect and hold Sensitive Information (such as information relating to health, disability, ethnic origin, criminal convictions, religious or political opinions), we will only do so where it is reasonably necessary to perform our functions and will seek your express written consent in advance.

How do we use the information that we collect about you?

We use personal information to conduct our business, to provide and promote our products and services and to engage in other business transactions involving our customers. Most commonly, we use this information to:

• provide services to you;
• administer and manage those services, including charging, billing and collecting debts;
• verify your identity;
• assist you to clarify and access any of our relevant services more easily;
• communicate with you, including through marketing communications;
• learn of your likely preferences so that we may promote our products and services in a way which may be of most interest to you;
• gain an understanding of your information and needs in order for us to provide you with better, more personalised services that are tailored to your needs;
  conduct appropriate checks for fraud;
• assist in investigating your complaints and enquiries;
• research and develop our services using third party services;
• maintain and develop our business, systems and infrastructure, including testing and upgrading of these systems;
• maintain and update our internal record keeping;
• comply with legislative and regulatory requirements;
• and engage in any other activity relating to our business as long as it complies with all relevant law.

How do we disclose information?

We will only use or disclose your personal information for the reason that we obtained or collected it. We will only share your personal information with third parties where there is a legitimate business reason for doing so. For example:

• we may share your personal information with third party IT support providers for the purpose of system administration and recovery, data security, data storage and retaining back-ups.
• If you are a client who has engaged with us in a project, we may share your personal information with other sub-contractors where they have been contracted to provide you with specialised services within that project.

In such cases, third-party service providers cannot use your personal data for their own purposes, but only specified purposes in accordance with our contract with them.

Exceptions include:

• you’ve consented to Leap Sustainability using or disclosing your personal information for a secondary purpose;
• we believe it is reasonably necessary for enforcement-related activities carried out by, or on behalf of, an enforcement body;
• a secondary purpose is required or authorised under an Australian law, or court or tribunal order;
• If you have been a participant in one of our research projects (such as stakeholder research), we will only re-contact you if this was agreed prior to participating in the research or if there is a genuine reason that justifies re-contact.

We will destroy/de-identify research information once the research purposes have been fulfilled.

We do not sell your personal information to third parties.

How long do we use your information for?

We only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data security

We will take all reasonable steps to protect the Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Security of digital data is supported by cloud-based technology that provides a high level of data protection as data is automatically synchronised and saved on servers in a secure data centre managed by Microsoft (Microsoft Privacy Statement).

We have put in place procedures to deal with any suspected data security breach and will inform you and any applicable regulator of a suspected breach where we are legally required to do so. We will take reasonable steps to ensure that any third-party vendors deal with personal information in a way that is consistent with the Privacy Act; however in providing your information to us via third-party platforms (such as Twitter or LinkedIn), you acknowledge that we cannot prevent the use (or misuse) of personal information by others.

If you become aware of any potential data security breach involving personal information provided to Leap Sustainability, please contact us as indicated below.

How to access and correct information

If you have provided personal information to us, or if your personal information has been supplied to us by a client, you have the right to request any and all of the information that was obtained or collected from you. We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). You may also request correction of information we hold about you if you believe it to be incorrect.

Before we provide you with access to your personal information, we may require some proof of identity.

There are some circumstances where we can refuse to give access to information. These include where given access to the Information would:
(a) pose a serious threat to the life, health or safety of an individual or the public;
(b) have an unreasonable impact on the privacy of others; or
(c) be frivolous or vexatious.

The other exceptions are detailed in the APPs.

You can request this information by contacting Leap Sustainability (as per ‘Contact Us’ below).

Our expectations of you

If you access or use our data improperly, including wrongfully accessing, disseminating, copying, using, streaming or otherwise publishing any of the content, we will support prosecution of you to the fullest extent permissible by law and you will fully indemnify us in relation to any damages, fines, costs, and penalties that may flow from your wrongful conduct.

Changes to this privacy policy

We will give you notice of these changes by publishing a revised Privacy Policy on the Website – we will not separately notify you of these changes.

Your acceptance

By using this this Website, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Website. Your continued use of the Website following the posting of changes to this policy will be deemed your acceptance of those changes.

Contact Us

If you have any queries about this Privacy Policy or how we handle your personal information, please contact: info@leapsustainability.com.au

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). Details about submitting a complaint to the OAIC are found here.

Updated February 2023