Privacy Policy

1. Application and Our Commitment

1.1. This privacy policy (‘Privacy Policy’) applies to each of our Group Entities. In this Privacy Policy a reference to ‘we’, ‘us’ or ‘our’ is a reference to each and any Group Entity.

1.2. In this Privacy Policy each of the following is a Group Entity:

  • The Brook Early Education and Care Pty Ltd A.C.N. 610 447 526 (which conducts our childcare centre at 19 Suez Street, Gordon Park);
  • Avco Pocket Pty Ltd A.C.N. 638 908 371, Red Duck Pocket Pty Ltd A.C.N. 638 908 399 and STJOCC Pocket Pty Ltd A.C.N. 638 908 880 (which conduct our childcare centre at 80 Boomerang Road, St Lucia);
  • St Clare Property Group Pty Ltd A.C.N. 629 293 965 which provides services for our other entities or businesses;
  • any entity that is affiliated with, or is related to, any of the abovementioned entities;
  • any person who is an employee of any of the abovementioned entities; and
  • any person who is an agent of any of the abovementioned entities. 1.3. This policy explains how we collect, manage, use and protect Personal Information, including but not limited to Personal Information collected on our websites, social media pages, via telephone and email, and controlled widgets embedded in any communication platform with a link to this Privacy Policy.

1.4. For the purpose of this policy, “Personal Information” means information about an identified individual or an individual who is reasonably identifiable.

1.5. We are committed to respecting the privacy and confidentiality of your Personal Information and we are required to act accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Types of Personal Information

2.1. In order for us to provide our products and services to you, we are required to collect Personal Information relating to you and your child. The types of Personal Information we may collect include, but are not limited to, the following:

  • Personal Information relating to you such as your name, date of birth, contact details, drivers’ licence number, tax file number, residency status, qualifications and employment details;
  • Personal Information relating to your child such as your child’s name, date of birth, orders, medical history, dietary requirements, language spoken, emergency contact details and medical practitioner’s details;
  • Enrolment history and details of attendances at our childcare centres;
  • Details relating to any government funding and your Centrelink Customer Reference Number; and
  • Financial Information such as your card payment details. 2.2. We will generally collect Personal Information from you directly through our websites, forms, or via email or telephone. We may also collect Personal Information from other indirect sources such as an enrolment from one of our childcare centres or from an affiliate company, a competition or promotion we conducted or endorsed or an employment application by you.

2.3. You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g. Facebook and LinkedIn). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with our services and authorising us to have access to this information, you agree that we may collect, store and use this information in accordance with this Privacy Policy.

3.1. We collect, manage and use Personal Information relating to you and your child with the aim of allowing us to deliver our services to you whilst protecting the development and wellbeing of your child.

3.2. We may use Personal Information we collect about you or your child for purposes such as, but not limited to, the following:

4.1. We may share Personal Information relating to you or your child to any person and in such a manner as is reasonably necessary to enable us to provide our services to you. These third persons may include:

3. Using Personal Information

  • to determine your child’s eligibility for enrolment in our childcare centres;
  • for the provision of our products and services (e.g. managing the progress of your child’s education and learning);
  • for safety and security purposes (e.g. determining your child’s health and medical risks);
  • for internal business development (e.g. risk management and training of our staff);
  • to improve our customer service and dispute resolution processes;
  • for marketing, statistical and promotional research (e.g. to notify you of our programs, events and special offers);
  • to investigate prohibited or illegal activities;
  • to comply with any applicable laws; and
  • for any other purposes to which you have consented.

4. How we share Personal Information with other parties

  • our affiliates, partners, suppliers and related companies;
  • service providers engaged by us from time to time in connection with the provision of services to you (including providers that are necessary to maintain the health and care of your child);
  • child protection or family support agencies in the event that we have reasonable concerns relating to your child;
  • financial institutions or any other organisation engaged by us for the purpose of providing banking facilitates necessary for the provision of our services;
  • entities that we plan to merge with or be acquired by or who may invest in us;
  • law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to us; or when we believe, at our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of our agreement with you;
  • your nominated referees, emergency contact or medical practitioner to verify information provided by you; and
  • (h) other third parties with your consent or direction to do so. 4.2. You acknowledge that any of those third parties may be situated in a country outside Australia, where the privacy laws may be less stringent than in Australia. When we disclose your Personal Information to an entity outside of Australia, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with appropriate standards for the handling of Personal Information.
  • 3. We will only share your Personal Information with third parties as described in this Privacy Policy, as otherwise notified to you at the time of collection or otherwise with your consent.

5. Consent and Sensitive Information

  • 1. We may request you to provide your consent for us to use and/or disclose your Personal Information if we need to use your Personal Information for a purpose that is not related to our services or for which it was collected.
  • 2. We understand that certain Personal Information requested by us may be sensitive (e.g. your child’s country of origin). We will ensure that any sensitive information collected by us will be stored in accordance with strict guidelines and procedures.
  • 3. However, if there is sensitive information that you do not wish to disclose to us, we ask that you speak to one of our representatives who will advise you of the impact this may have on you or your child and to discuss any alternatives that may be available to you.

6. What if I do not provide my consent?

  • 1. You acknowledge that if you refuse to provide your Personal Information or consent (where required) or refuse to provide your consent to us providing your Personal Information to third parties then this may affect the provision of our services to or for you.

7. Controlling Online Interest-Based Ads

  • 1. We sometimes work with online advertising vendors to provide you with relevant and useful advertisements (ads). This may include ads served on or through our websites or on other persons’ websites. These ads may be based on your activities on our websites or on third party websites.
  • 2. Our websites may use Google Analytics, a web analysis service of Google Inc. (‘Google’). Google Analytics uses Cookies to monitor traffic to, and use of, our websites. Google uses this information on our behalf to evaluate your website usage, to compile reports on the website’s activities, and to provide additional services connected with our websites. We will not identify you to Google and we will not merge personal and non-personal information collected through this service. You can prevent the use of Google Analytics Cookies by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of our websites if you do so.
  • 3. In addition to Google Analytics, we may also use other third-party analytics tools to monitor, analyse and collect information about your use of our websites.

8. What about marketing and subscription?

  • 1. We may use your Personal Information from time to time to send you marketing information about our special promotions, offers, events and programs. You may unsubscribe from these marketing materials or update your preferences (e.g. change the means of communication) by using our websites, by contacting us or selecting the unsubscribe option on each marketing material we send to you.
  • 2. You acknowledge that unsubscribing from marketing materials may take up to 14 days to process. Once you have unsubscribed, we may still continue to contact you for other transactional or information purposes.

9. What about cookies and browsing services?

9.1. We use cookies for certain areas of our websites, which are small files of data that are placed on your internet browser. These are used to enhance your user experience by offering more tailored and efficient online service. For example, by using cookies your personal details and password may be stored on the browser and will automatically populate next time you visit the website.

9.2. We also use cookies to better understand your activities on our websites and third party websites. We may share information generated by these cookies to third party analytics or online advertising vendors who may use this information to evaluate your webpage activities and tailor their advertising to you.

9.3. You are able to disable or block some or all cookies through the setting function of your browser. However, by disabling or blocking cookies you may interfere with your access to, and the functionality of, some or all parts of our website and the provision of our services to you.

10. Protecting Personal Information

0.1. We will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure. For example, we will ensure that only employees of The Pocket and authorised personnel are given access to your Personal Information.

10.2. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.

10.3. We review our internal and technological processes regularly to ensure that we provide your Personal Information with a high level of protection. However, despite the steps that we take, we cannot guarantee that your Personal Information will be absolutely secure.

10.4. By providing your Personal Information to us, you agree to accept all security risks associated during the transmission of your Personal Information to us and you acknowledge that once we receive your information, we will take reasonable steps to secure and safeguard your Personal Information.

11. Our Legal Obligations

11.1. We take the privacy of your Personal Information seriously and in addition to safeguarding your rights under this Privacy Policy, we also ensure strict compliance with our legal obligations relating to your Personal Information.

11.2. We ensure that we comply with our legal obligations under the Privacy Act 1988 (Cth), such as notifying you about any eligible data breaches, and the Spam Act 2003 (Cth), such as monitoring the amount and content of electronic messages we provide to you.

12. Your rights

12.1. Subject to any agreements you may have with us and any applicable law, you have certain rights to your Personal Information that we hold. These include:

  • you may access Personal Information relating to you and your child. We will endeavour to deliver information requested by you within a reasonable time and in a reasonable manner and should we refuse to supply the information requested, we will notify you of the reason for our decision;
  • you may update or correct your Personal Information at any time by contacting us; and
  • you may instruct us to stop using your Personal Information for direct marketing purposes.

13. Changes to this Privacy Policy

13.1. We may update our Privacy Policy from time to time. Any change made to our Privacy Policy will be effective once it is posted on our website. We may notify you via email or mail of any change to the Privacy Policy which we believe materially affects you. We recommend that you check our website frequently for any changes or updates to our Privacy Policy.

13.2. Please make a request to us directly if you require us to notify you of any updates made to this Privacy Policy.

14.1. If you have any concerns or queries regarding your Personal Information, this Privacy Policy or if you wish to exercise your rights under this policy, please contact us directly as follows:

14.2. We aim to acknowledge receipt of all correspondence from you within 5 Business Days and to resolve all matters within 21 Business Days. Where we cannot answer your query within 21 Business Days, we will notify you promptly of this, the reason for the delay and an anticipated response date.

14.3. If you are not satisfied with the way we handle your query, you may contact the Office of the Australian Information Commissioner directly to discuss.

14. Queries or Complaints

St Clare Property Group Pty Ltd