Privacy Policy

This privacy policy applies to all Personal Information collected by Skilli Pty Ltd A.C.N. 665 114 858 (We, Us or Our) via the mobile application known as “Skilli” (App).

Australia Specific - Types of Personal Information
1. The Australian Privacy Act 1998 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.
  1. Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:
    1. whether the information or opinion is true or not; and
    2. whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.

1. 1. Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Sensitive Information will be used by Us only:
    1. for the primary purpose for which it was obtained (for example, your health information may be reasonably exchanged in connection with the quoting or provision of the Coaching);
    2. for a secondary purpose that is directly related to the primary purpose; and
    3. with your consent or where required or authorised by law.
What information do We collect?
1. The kind of Personal and Sensitive Information that We collect from you will depend on how you use the App. The Personal and Sensitive Information which We collect and hold about you may include:
  1. your name, address, email address, phone number and other contact details;
  2. your credit card and account details, which are processed by a third party service provider that handles payments between the Coach, Student, our App and such other parties as may be connected to an offering;
  3. your occupation, online profiles, social media links age, physical criteria, qualifications, professional or amateur experiences, skillsets, interests, resume, referees and certifications;
  4. your location, interests, target markets, information relevant to your circumstances as a Coach or as a Student;
  5. your photograph and, if you have uploaded such things, your medical information or other personal data in respect to your physical health, ailments or alike for purposes of Coaching;
  6. your interests, associations, memberships and other information which may be relevant to you, whether or not related to the provision of or receipt of a Coaching opportunity;
  7. your personal preferences in respect to race, religion or other criteria which effects your engagement with or by a Student or Coach;
  8. police or other law enforcement checks, as well as other validating information in respect to you or your offering or request for Coaching;
  9. your charging rates, scheduling preferences and diary and such other information as you may upload related to your services as a Coach (if applicable); and
  10. in respect to your use of the App, we may also collect information in respect to your usage, including transactions you have entered into or the Coaching you have required or received, any feedback ratings logged in respect to your use, changes made by or in respect to you, comments posted by or about you and the transactions you enter into through our App generally.
2. We may also collect information about you from third party verification providers, such as police history checks, identity verification services, credit reporting information, data or marketing service providers and other third party supplied data.
3. As an active user of the App, the data you contribute will not be given sensitive status, where the information relates to feedback on postings, offers for services, quotes, requests for services or comments about a Coach or a Student. The exception to this is the information which is contributed by or on behalf of you which is Sensitive Student Information or Sensitive Coach Information.
Sensitive Information
1. Sensitive Student Information: The following information you contribute to the App will be kept “sensitive” except as you direct to be provided to a prospective Coach (except as shown below, all other information contributed by you to the App must be assumed by you to be available publicly and for use by Us in the operation of the App):
  1. your credit card or other account details (excepting that this information will be exchanged with the third party service providers responsible for collecting and disbursing monies in conjunction with the Coaching);
  2. your date of birth (except as required for the provision of Coaching); and
  3. your medical records (except as required for the provision of Coaching).
2. Sensitive Coach Information: The following information you contribute to the App will be kept “sensitive” except as you direct to be provided to a prospective Coach (except as shown below, all other information contributed by you to the App must be assumed by you to be available publicly and for use by Us in the operation of the App):
  1. your credit card or other account details (excepting that this information will be exchanged with the third party service providers responsible for collecting and disbursing monies in conjunction with the Coaching);
  2. your date of birth (except as required for the provision of Coaching); and
  3. your medical records (except as required for the provision of Coaching).
Minor Persons
1. This App may not be used by a Minor Person (including but not limited to the facilitation of a Coaching on behalf of a Minor Person.
How We collect your Personal Information
1. We may collect Personal Information from you whenever you input such information into the App, related app or provide it to Us in any other way.
2. We may also collect cookies from your device which enable Us to tell when you use the App and also to help customise your App experience. As a general rule, however, it is not possible to identify you personally from Our use of cookies.
3. We may also obtain information about you from other sources, such as social media sites which are connected to your identity or information which is contributed to the App or through other connections we may make with you otherwise.
4. We generally do not collect Sensitive Information (except as noted above in respect to the Coaching assessment and provisions), but when We do, We will comply with the preceding term.
5. Where reasonable and practicable We collect your Personal Information from you, your Student or your Coach only. However, sometimes We may be given information from a third party, and in cases like this, We will take reasonable steps to make you aware of the information that was provided by a third party.
Purpose of collection
1. We collect Personal Information to provide you with the best service experience possible on the App and keep in touch with you about developments in the App.
2. We customarily disclose Personal Information to Our service providers who assist Us in operating the App and in the exchange of details as reasonably necessary to assist the assessment and engagement between Students and Coaches.
3. We may provide your Personal Information in association with the Coaching as is reasonable to maximise the benefits of the opportunities provided through the App, including but not limited to linking your performance or experience to your associated social media platforms, to amateur and professional associations and other media bodies. This use will generally be directed by you (as a Coach or Student).
4. Where Coaching is offered or provided, we may collect and exchange your Personal Information with law enforcement or other assessment authorities for purposes of undertaking security checks and/or validating qualifications.
5. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
6. We may use your Personal Information to validate your identification and other information.
7. We may use your Personal Information to assess any legitimate risk to person or property associated with any Coaching offered or accepted by a Student or Coach.
8. We may use your Personal Information for data collection and analytics to assist Us in improving our App and associated services.
9. By using Our App, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if We have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from use. We do not use sensitive Personal Information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe button link.
Other information on how we may share your Personal Information
1. As a facilitator App, Your Personal Information will be exchanged in the ordinary course of the offer, acceptance and provision of Coaching between Students and Coaches. Excepting to the extent that your Personal Information is classified as Sensitive Student Information or Sensitive Coach Information, your Personal Information will not otherwise be kept sensitive on the App where it relates to comments, offers, quotes, engagements, feedback and profile data which is published by you as a Student or Coach.
2. We may share your Personal Information to third party providers for processing of payments, for validation of identification or qualifications or other similar purposes connected to the giving or receiving of Coaching.
3. We may share your Personal Information with our own service providers who assist Us with marketing, data analytics and other lead sourcing.
4. We may share your Personal Information as requested by law enforcement or other authorities with lawful rights to access the information.
5. We may Share your Personal Information for our own financial purposes, including raising funding, selling any part or parts of our business, for restructuring or expansion and potentially, in the event of insolvency, then with a receiver or trustee in bankruptcy.
6. We also will share your Personal Information on such other terms and conditions requested by you and approved by Us.
Security, access and correction
1. We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When We no longer require your Personal Information for the purpose for which We obtained it, We will take reasonable steps to destroy and anonymise or de-identify it. However, most of the Personal Information that is stored in Our client files and records will be kept for a minimum of 2 years to fulfill Our record keeping obligations.
2. The Australian Privacy Principles (APP):
  1. permit you to obtain access to the Personal Information We hold about you in certain circumstances (APP 12); and
  2. allow you to correct inaccurate Personal Information subject to certain exceptions (APP 13).
3. Where you would like to obtain such access, please contact Us in writing on the contact details set out at the bottom of this privacy policy.
Complaint procedure
1. If you have a complaint concerning the manner in which We maintain the privacy of your Personal Information, please contact Us on the contact details set out at the bottom of this privacy policy.
2. All complaints will be considered by [Our privacy officer] and We may seek further information from you to clarify your concerns. If We agree that your complaint is well founded, We will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).
Overseas transfer
1. Your Personal Information may be transferred overseas or stored overseas for a variety of reasons. It is not possible to identify each and every country to which your Personal Information may be sent. If your Personal Information is sent to a recipient in a country with data protection laws which are at least substantially similar to the APP, and where there are mechanisms available to you to enforce protection of your Personal Information under that overseas law, We will not be liable for a breach of the APP if your Personal Information is mishandled in that jurisdiction. If your Personal Information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia's, We will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the APP.
How to contact Us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about Our privacy practices, you can contact Us on: info@skilliapp.com.au

Dated: [include date of last update]