1. “We”, “us”, “our” and “the Company” means The Long Game Project pty ltd ACN 663 643 641.
3. We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way that personal information must be treated.
4. By providing your details, you consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
1. This policy applies to any person in relation to whom we currently hold, or may in the future collect, personal information. Broadly, we collect personal information from our users, prospective users and other individuals that contact us with enquiries, prospective and current contractors, consultants and agents, prospective employees and third parties and their employees with whom we or our users have a business or commercial relationship.
2. This policy does not apply to acts and practices in relation to ‘employee records’ of our current and former employees, as these are exempt from the Privacy Act.
1. This policy applies to personal information (including sensitive information). In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.
2. Information is not personal information where the information cannot be linked to an identifiable individual.
Anonymity and pseudonymity
1. We will take reasonable steps to destroy or de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
2. If you want to use a pseudonym or remain anonymous when dealing with us, you should notify us and we will try to accommodate your request, subject to our ability to interact with you without having your personal information.
3. You do not have to provide your personal information to us but if you do not provide the information requested by us, we may not be able to provide you with our products or services or otherwise engage with you.
2. Personal information
1. Our website at ‘www.longgameproject.org’ (Website) automatically collects information about your computer hardware and software including:
1. your IP address;
2. your browser type;
3. the types of devices you are using to access the Website;
4. language and operating system;
5. domain names, access times and referring website addresses;
6. page clicks, time spent and other automatically collected meta-data
1. The personal information we may collect differs, depending on the nature of our interaction with you.
2. If you are a customer or prospective customer (or an individual representative of, or individual otherwise involved with, such), we may collect and hold personal information about you, which may include:
1. contact information;
2. financial information;
3. date and place of birth;
4. your history of purchases;
5. details of enquiries or complaints that you make;
6. transaction details including post purchase transactions; and
7. any other personal information required to provide our products and services.
3. Our Website also collects usage information from customers. Broadly, this information relates to how you use and navigate the Website, including:
1. data relating to choice selection if you chose to engage with an interactive feature of the Website;
2. information about pages, content or advertisements you have browsed or clicked on; and
3. any content, information or material you disclose to us or other users.
4. If you are a prospective or current contractor, consultant or agent, or prospective employee or a third party or their employee with whom we or our users have a business or commercial relationship, we may collect and hold personal information about you, which may include:
1. contact information;
2. date of birth;
3. employment history;
4. tax file number information;
5. insurance information and claims history;
6. licence details;
7. education details;
8. driving history;
9. banking details;
10. government related identifiers, such as passport numbers and driver’s licence numbers;
11. any other personal information required to engage you as our contractor, consultant, agent, employee or in any other capacity; and
12. records of contact and details of enquiries, conversations or correspondence made or received with you.
1. The type of personal information we may collect and hold differs depending on the nature of our interaction with you.
2. Sensitive information is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately. For example, sensitive information may include but is not limited to:
1. health information;
2. racial or ethnic origins;
3. sexual orientation;
4. political opinions or associations; and
5. religious or philosophical beliefs.
3. Sensitive information may be disclosed to us if you choose to disclose, publish or share such information on our Website or any communication platform linked to our Website.
4. We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.
2. How do we collect personal information?
1. We may collect personal information directly from the individual concerned for example via:
1. the Website, including its interactive features;
2. any sites or programs linked on the Website including social media and communication platforms;
3. online forms or surveys;
4. telephone calls; and
2. Personal information may also be collected from third parties such as:
1. users of the Website;
2. your representatives and advisers;
3. through referrals from individuals or other entities;
4. from banks and financial institutions;
5. your current and previous employers;
6. government bodies (such as relevant departments, regulatory authorities etc.);
7. our employees, contractors and agents;
8. paid search providers; and
9. through marketing and business development events.
1. Our Website uses ‘cookies’, a text file that is placed on your hard disk by a webpage server. Cookies are uniquely assigned to you.
2. A cookie notifies the webserver that you have returned to a specific page. For example, if you personalise our webpage or create an account on our Website, a cookie:
1. helps us to recall your specific information on subsequent visits; and
2. simplifies the process of recording your personal information.
3. You have the ability 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.
2. How do we hold personal information?
1. All the information is kept electronically, in computer systems and databases (including cookies) either operated by us or our external service providers.
2. We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
3. Some of these processes and systems include:
1. using secure servers to store personal information;
2. arranging for our employees to complete training about information security;
3. holding certain sensitive documents securely; and
4. monitoring and reviewing our policies.
4. Though we take these measures to keep your information secure, we cannot guarantee that your information will remain secure or that it will only be disclosed in a manner consistent with this policy.
3. Why do we collect, hold, use or disclose personal information?
1. We take reasonable steps to hold, use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which we collect information varies depending on the individual that we are collecting the information from but is generally as follows:
1. in the case of users and prospective users, to provide our products and services, which may also involve:
1. facilitating transactions;
2. keeping records of transactions to assist in future enquiries and improve our Website, products and services;
3. providing support relating to our products and services;
4. maintaining records of your content and email preferences;
5. providing you with updates that are relevant to you;
6. managing and performing any contract entered into with you;
7. helping us identify and develop products and services that may interest you;
8. maintaining and enhancing our relationship with you;
9. conducting market or user satisfaction research;
10. conducting promotions and inviting you to events, both physical and virtual;
11. making you aware of new and additional products, services and opportunities;
12. improving our products and services and gaining a better understanding of your needs;
13. recording and analysing usage and performance of our Website; and
14. ensuring compliance with legislative and regulatory requirements.
2. in the case of a current contractor, consultant, agent, or third parties and their employees with whom we or our users have a business or commercial relationship to assist us in providing our products and services;
3. in the case of a prospective contractor, consultant, agent, employee or a third party and their employees with whom we or our users may wish to have a business or commercial relationship with, to assess your suitability for employment or engagement; and
4. to protect the copyright, trademarks, legal rights, property and safety of the products and services, Website and users of the Company and our related entities.
2. Personal information may also be used or disclosed by us for secondary purposes that are within your reasonable expectations and that are related to the primary purpose of collection.
3. We may disclose personal information to:
1. our contractors, subcontractors, suppliers, consultants, agents, employees, officers or other third parties with whom we or our users have a business or commercial relationship;
2. government bodies (such as relevant departments, regulatory authorities etc.);
3. emergency service providers and law enforcement agencies;
4. our external auditors, brokers and insurance providers and legal and other advisers;
5. employers of individuals;
7. third parties considering the acquisition of the whole or part of our assets or business, or that acquire the whole or part of our assets or business; and
8. our related entities.
4. We will only disclose personal information to third parties if:
1. we are required or authorised by law to do so, including under a regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a request from a law enforcement agency;
2. we have received express consent to the disclosure, or consent may be reasonably inferred from the circumstances; or
3. we are otherwise permitted to disclose the information under the Privacy Act.
5. You acknowledge that if we disclose personal information to government bodies (such as relevant departments, regulatory authorities etc.), the collection, use and disclosure of that personal information may be regulated by other relevant legislation such as the Right to Information Act 2009 (Qld).
4. Will we disclose personal information outside Australia?
1. In some cases, we may indirectly disclose personal information overseas through disclosures to our contractors and service providers that have data servers located overseas.
2. Where we disclose your personal information to parties located overseas (or which have data centres located in other countries), we take reasonable steps to ensure that those parties will handle the personal information in accordance with the Australian Privacy Principles. We are not required to take such steps if we believe that the overseas recipient is already subject to a law that has the effect of protecting personal information in a substantially similar way to the relevant law in Australia, or with your consent.
5. How do you make complaints and access and correct your personal information?
1. It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
1. You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
2. We will grant you access to your personal information as soon as possible, subject to the request circumstances.
3. In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
4. We may deny access to personal information if:
1. the request is unreasonable;
2. providing access would have an unreasonable impact on the privacy of another person;
3. providing access would pose a serious and imminent threat to the life or health of any person; or
4. there are other legal grounds to deny the request.
5. We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
6. If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it where it is appropriate to do so.
1. If you would like to complain about an interference with your privacy, then you must follow the following process:
1. the complaint must first be made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint; and
2. if the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
1. A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Email address: email@example.com
1. Changes to the policy
1. We may update, modify or remove this policy at any time without prior notice.
2. This policy is effective 22/2/2023. If you have any comments on the policy, please contact the Privacy Officer with the contact details in section 8.9 of this policy.