The information that we collect depends on the nature of your interactions with us. We collect both personal information and non-personal information. In this Policy, personal information has the meaning given to it in the Privacy Act 1988 (Cth), and includes information or an opinion, whether true or not, about an identified individual or an individual who is reasonably identifiable.

We may collect personal information about: (a)our clients, business associates, potential clients and their personnel; (b) other individuals in the course of acting for our clients; (c) our suppliers and their employees; (d) our members, which shall include those noted in c above, and also directors or principals, employees, partners, contractors, and any of the aforementioned who were formerly in such category; and (e) other people who come into contact with Thrace, including the above aforementioned.

In general, the personal information we may collect and hold includes name, date of birth, contact details (including email addresses), occupation, company name, username and password (as applicable), personal preferences, payment details, employment history, education and qualifications, testimonials and feedback, and other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations. In some cases we may also collect 'sensitive information', such as information about an individual's membership of a professional association, criminal record or health information.

We may also collect and process non-personal information provided to us by your browser when you visit our websites or use our applications, for example, the website you came from, your location information, IP address, web browser and/or device type and the time and date of access.

We will generally collect personal information: (a) from you directly when you provide your details to us; (b) from you indirectly through emails, forms, face-to-face meetings, interviews, registration and attendance at seminars, business cards, online queries and telephone conversations, and through use of the services available through our websites, applications and social media channels (including our blogs and LinkedIn channels); and (c) from third parties in some instances, for example, we may use third parties to analyse traffic at our website, our blogs and social media channels, which may involve the use of cookies. You are able to control your browser settings to limit the collection of cookies by us; however, if you choose to disable cookies, you may not be able to use certain features of our websites. In some circumstances we may collect personal information about an individual from a third party, for example, a report provided by a medical professional or an employment reference from another person.

If you are an individual in a country in the European Economic Area (EEA), we may be required to comply with the EU General Data Protection Regulation 2016/679 (the GDPR) as it may apply to us when processing the personal information of individuals (data subjects) who are in countries in the EEA in relation to offering you our products or services or if we monitor any of your behaviour when in those countries. This includes additional information we are required to tell you about in relation to your privacy, including the basis on which we collect your personal information and your data subject rights under the GDPR.

We will take reasonable steps to protect the security of personal information. We are required to respect the confidentiality of personal information and the privacy of individuals. We take reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where we no longer require your personal information we will take reasonable steps to destroy or de-identify it.

In general, we may collect, hold, use and disclose your personal information for the primary purposes for which it was collected, including: (a) to provide and market our products or services; (b) to conduct our business; (c) to communicate with you to provide or promote our products or services; (d) to purchase goods or services; (e) to help us manage, develop and enhance our services, including our websites and applications; (f) to consider the suitability of prospective employees; (g) to comply with our legal obligations; (h) and to administer, maintain, support, and provide upgrades to, our services and applications.

We may also use and/or disclose your personal information for other purposes which you consent to, or which are required or permitted by law. This may include for a secondary purpose that is related to a purpose for which we collected it, and for which you would reasonably expect us to use or disclose your personal information.

If at any time you would like to unsubscribe from receiving future content, surveys, features or other marketing information or communications, we include in all electronic messages a statement to the effect that you, as the recipient, may send an unsubscribe message to us using the contact details provided in that electronic message.

 We may disclose your personal information (including, in certain limited circumstances, your sensitive information) for the purposes for which it was collected (as described above) to: (a) members of Thrace, save for when we are precluded from doing so due to specific obligations in respect of confidentiality;(b) entities who assist us in providing our services (including hosting and data storage providers and debt collectors); (c) social media channels on which we have a presence, including LinkedIn; and (d) where we are required or authorised to do so by law.

We may disclose your personal information to the following overseas recipients: (a) companies or individuals who assist us in providing services or who perform functions on our behalf (such as third party service providers, specialist consultants and barristers), including those located in the USA; (b) to courts, tribunals and regulatory authorities; (c) to anyone else to whom you authorise us to disclose it; and (d) to anyone else where we are required or authorised by law to do so.

We may provide links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. If you visit these websites, they will be governed by their own terms of use (including privacy policies).

Subject to the exceptions set out in the Privacy Act, you may seek access to and correction of the personal information which we hold about you by contacting us at info@thrace.com.au.  We will require you to verify your identity and to specify what information you require. If a fee is charged for providing access, you will be advised of the likely cost in advance.

This Policy will be reviewed and updated for from time to time to take into account new laws or changes in law, changes in technology, changes to our operations and practices, the changing business environment, or for any other reason.

If you have any queries or concerns about this privacy policy or the way in which Thrace handles your personal information, please contact us at info@thrace.com.au

For more information about privacy in general, you can visit the Federal Privacy Commissioner’s website at www.privacy.gov.au.