Reflective Insights
Privacy Policy 

1. We respect your privacy 

Reflective Insights Pty Ltd (ACN 635 740 162) (“our,” “we,” or “us”) respects your right to privacy and is committed to safeguarding the privacy of our clients and website visitors.   

Privacy and confidentiality are of paramount importance to Reflective Insights. 

We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This privacy policy sets out how we collect, use and protect your personal information. 

“Personal information” is information which we hold which is identifiable as being about you (or from which your identity may reasonably be ascertained) – examples include your name, postcode and contact details.  It may also include financial information. 

Reflective Insights is committed to ensuring that your privacy is protected. Should we ask you to provide personal information, then you can be assured that it will only be used in accordance with this privacy policy.  

Please read this privacy policy carefully, before continuing to use this website or otherwise engaging or receiving our services. By visiting our website or otherwise engaging or receiving our services, you are accepting the terms of this privacy policy without limitation or qualification.  

We may change this policy from time-to-time by updating this page and all modifications will be effective immediately upon our posting of the modifications on this page.  

You should check this page periodically to ensure that you continue to consent to our privacy policy over time.

2. Collection of personal information

Reflective Insights will, from time to time, receive and store personal information that you enter onto our website or social media platforms, that you provide to us directly, that we obtain as part of our provision of services to you or which is given to us in other forms. 

You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your services.  You may also provide detailed business information to us as part of our services.  We may also collect information about your computer and connection information, details of the services that you have enquired about and any other personal information that may be required in order to facilitate your dealings with us. 

We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our consultants or customer support. 

Additionally, we may also collect any other information that you provide while interacting with us. 

Generally, we collect your personal information to provide you with services and to administer our relationship with you. We also collect personal information for marketing purposes and to provide you with information about special events and services that may be of interest to you. 

3. How we collect your personal information 

Reflective Insights collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website, when you provide a request for service or otherwise discuss your service needs with us, when you pay for our services and when we provide our services to you. If we do, we will protect it as set out in this privacy policy. 

If you feel that information that we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us. 

If you provide to us the personal information of another person, you warrant that the person or persons to which the personal information relates has consented to such disclosure and to our collection, holding, use and disclosure of their personal information as described in this privacy policy. 

4. Use of your personal information 

Reflective Insights has strict policies with respect to who has access to your information. 

Reflective Insights may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve services and better understand your needs. 

We and/or our carefully selected business partners may send you direct marketing communications and information about our services.  This may take the form of a telephone call, email, SMS or mail in accordance with the Spam Act and the Privacy Act. If you do not wish to receive marketing or other communications from us, please contact us so that we can update your preferences (or use the opt-out facilities provided, such as an unsubscribe link).

5. Disclosure of your information 

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.  

We may also share business data, which may include your personal information, with our cloud service providers strictly for the purpose of our provision of services to you. 

Personal information is only supplied to a third-party when it is required for the delivery of our services, payment for our services or otherwise required at law.  

We may also use your personal information to protect our copyright, trademarks, legal rights, property or safety or that of our clients or third parties.  

We store client information and information relating to our clients, including personal information, in cloud service providers with data hosting in Australia.  Please note that Microsoft is our primary cloud provider.  Please be aware that Microsoft has data centres in Singapore and the United States of America (amongst others) which we may use from time to time.  We will use our reasonable endeavours not to store client data or personal information with Microsoft’s international data centres.     

If we do need to share client data or personal information with Microsoft’s international data centres, we will take reasonable steps to ensure that those international data centres deal with such personal information in a way that is consistent with the Australian Privacy Principles. 

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.  

By providing us with personal information, you consent to the terms of this privacy policy and the types of disclosure covered by this privacy policy. Where we disclose your personal information to third parties, we will request that the third party follow this privacy policy regarding the handling of your personal information. 

6. Security of your personal informatioN

Reflective Insights is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. 

Once we no longer need your personal information, we take reasonable steps to de-identify your personal information. 

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this privacy policy. 

7. Sensitive information

Sensitive information includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs or details of health, disability or sexual activity or orientation.  We will not ask for sensitive information from you. 

8. Access to your personal information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth).  A small administrative fee may be payable for the provision of information.  If you would like a copy of the information which we hold about you or believe that any information that we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please message us here.  

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. 

9. Identifiers and anonymity

As required by the Australian Privacy Principles, we do not adopt, disclose or use Commonwealth government identifiers when interacting with you. 

Where practical, you may deal with us on an anonymous basis however, because of the nature of the services we provide, if you do not provide us with your personal information, we may not be able to provide you with the requested service. 

10. Questions or complaints about privacy

If you have any questions whatsoever on our handling of your personal information or the kind of personal information that we hold about you, please contact us on the details below and we will endeavour to assist you with your request. 

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to our privacy officer here. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. 

For information about privacy generally, or for individuals who have privacy concerns which they feel we have not resolved to their satisfaction, the Office of the Australian Information Commissioner can be contacted on 1300 363 992 or via http://www.oaic.gov.au.

11. Our website

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

Our site may from time-to-time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Reflective Insights is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

This policy is effective from November 2019.