Focus Learning Group Pty Ltd trading as “Play4Business” (ABN 55 128 613 427) (“we”, “us”, “our”, “the business” or the “company”) is committed to privacy protection. At https://play4business.com (“this site” or “the site”), we understand the importance of keeping your organisation’s personal information private and secure. This privacy policy (“Privacy Policy”) describes generally how we manage your organisation’s personal information and safeguard privacy. If you or your organisation (“you”, “your”) would like more information, please don’t hesitate to contact us.

When we collect, store and use your personal information, we do so in accordance with the rules set down in the Australian Privacy Act 1988 (Privacy Act).

This Privacy Policy forms part of, and is subject to the provisions of our Website Terms of Use (https://play4business.com/terms-of-use).

The Australian Privacy Principles

We will treat all personal information in accordance with any and all obligations that are binding upon Us under the Privacy Act 1988 (Cth) (“Privacy Act”) and the “Australian Privacy Principles” set out in the Privacy Act.

What is “personal information”?

“Personal Information” is information about you which:

• can be used to identify, contact or locate you;
• can be combined with other information that is linked to you; or
• is defined as “personal information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about you.

We collect the content, communications and other information you provide when you use our Platform and/or Services, including when you register on the Platform, create or share content on the Platform and communicate with others.

Personal information held by the company may include your:

• personal details including name, mailing or street address, email address, telephone number and other contact details, age or date of birth, your employment information;
• details of the Services We have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries;
• bank account and/or credit card details for agreed billing purposes;
• any additional information relating to you that you provide to Us directly through our Platform or app or indirectly through your use of our Platform or app or online presence or through other websites or accounts from which you permit us to collect information;
• preferences and password for using this site and your computer and connection information; and
• any information that you otherwise share with us.

Information provided to our Payment Partners

All purchases that are made through this site are processed securely and externally by our payment partners. our current payment partners are Stripe, PayPal, Apple Pay and Afterpay (Payment Partners). Unless you expressly consent otherwise, we do not see or have access to any personal information that you may provide to our Payment Partners, other than information that is required in order to process your order and deliver your purchased items to you (e.g. your name, organisation details, email address and billing address).

Why do we collect your personal information and how do we use your personal information?

We collect and use your personal information to operate our Platform and to deliver our Services. This includes:

• responding to your enquiries and requests, and providing you with our Services in response to such requests;
• providing, maintaining, protecting, and improving our Platform, technology, products and services;
• monitoring the effectiveness of our services;
• anything you authorise or consent to Us doing;
• notifying you in regard to changes or developments to our Platform and Services;
• administering, developing, and improving our Platform and Services;
• marketing our Platform and Services, sending you messages and follow-up reminders;
• responding to any complaints you have made regarding our Platform or Services;
• data analytics; or
• taking any action We are obliged to take in accordance with relevant laws and regulations.

How we may collect your personal information

We may collect personal information that you provide to us about your organisation or yourself when you:

• use this site, including (without limitation) when you:
  • create a user account;
  • add information to your user profile;
  • purchase any services through this site;
  • add reviews, forum or chat room messages or comments in any elements of this site that permit user-generated content;
  • register for access to premium content or request certain premium features; or
  • complete an online contact form to contact us;
• provide information to us by telephone or through marketing or competition application forms; or
• send us an email or other communication.

How can you access and correct your personal information?

• Access: You may request details of personal information that We hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth). An administrative fee may be payable for the provision of information. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may refuse to provide you with information that We hold about you, in certain circumstances set out in the Privacy Act. If We refuse to give you access, we will provide you with reasons for our refusal.
• Correction: If you believe that any information We hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact Us by email at info@play4business.com. We rely in part upon customers advising Us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.

When we may disclose your personal information

For the purposes set out above, We may disclose your personal information to other members of our corporate group and third parties outside the Company. Your personal information may be disclosed to these third parties who are contracted to carry out specialised functions, which will only be in relation to our business operations, functions and activities, and performance of services. We take reasonable steps to ensure that these third parties are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

In addition, We may disclose your personal information to:

• your authorised representatives or legal advisers (when requested by you to do so);
• our professional advisers, including our accountants, auditors and lawyers or the professional advisers of members of our corporate group;
• government and regulatory authorities and other organisations, as required or authorised by law;
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions;
• our employees, contractors and personnel and related bodies corporate;
• third party suppliers and service providers (including providers for the operation of our Platforms and/or our business or in connection with providing our products and services to you);
• as necessary to detect, prevent, or otherwise address fraud, security or technical issues; and
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

We may process and disclose personal information outside of the country of origin of that personal information. We may also store data, including personal information, in various countries such as Australia and the United States of America.

When you provide your personal information to Us, you consent to the disclosure of your information outside of Australia and acknowledge that We are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

IP addresses

The Platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. We collect and manage IP addresses as part of the service of providing internet session management and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving this Platform.

Cookies

This site uses “cookies” to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies” folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The company extends the same privacy protection to your information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

Why we use cookies

This site uses cookies in order to:

• remember your preferences for using this site;
• manage the signup process when you create an account with us;
• recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
• facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
• show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and
• remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).
• Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.

Children

We do not knowingly or specifically collect personal data from individuals under the age of 18 and no one under age 18 is authorized to submit any information, including personal data to us, via our site or otherwise.

If we determine that such information has been inadvertently collected on anyone under the age of 18, we will take the necessary steps to ensure that such information is deleted from our systems.

Re-marketing

We may use the Google AdWords, Linkedin and/or Facebook re-marketing services to advertise on third party websites to previous visitors to this Platform based upon their activity on this Platform. This allows Us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook or Linkedin. Google, Linkedin and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by them will be used in accordance with their own respective privacy policies. None of your personal Google, Facebook and/or Facebook information is reported to us.

You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.

Contacting us about privacy

If you would like more information about the way we manage the personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email at privacy@play4business.com or by post at PO BOX 333 St Leonards NSW 1590 Australia.

Complaints

If you have a complaint about the way in which we have handled any privacy issues, including your request for access or correction of your personal information, you should contact us by email at privacy@play4business.com or by post at PO BOX 333 St Leonards NSW 1590 Australia.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Keeping your information up-to-date

To ensure that your personal information is accurate and up to date, please promptly advise us of any changes to your information by contacting our data protection officer by email at privacy@play4business.com or by post to PO BOX 333 St Leonards NSW 1590 Australia.

Publication

This Privacy Policy will be made available to all users of this website and our services.

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. Any changes in our Privacy Policy will be posted to this website and will become effective as of the date of posting with respect to information we then collect in the future, but will not be changed with respect to information that we have then already collected. We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

Effective Date

This Privacy Policy is effective with respect to all data that we have collected since the date we started collecting data which was November 1, 2020.